SEC Comment Letter 0000000000-23-001670 to Lucas GC Ltd (LGCL)
Lucas GC Ltd
Date: Feb. 17, 2023 · CIK: 0001954694 · Accession: 0000000000-23-001670
AI Filing Summary & Sentiment
Reasoning
Letter
United States securities and exchange commission logo February 17, 2023 Howard Lee Chief Executive Officer Lucas GC Ltd Room 5A01, 4th Floor Air China Building, Xiaoyun Road Sanyuanqiao, Chaoyang District Beijing 100027, China Re:Lucas GC Ltd Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted February 3, 2023 CIK No. 0001954694 Dear Howard Lee: We have reviewed your amended draft registration statement and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Draft Registration Statement on Form F-1 submitted February 3, 2023 Cover Page 1.To the extent you intend to proceed with your offering if your NASDAQ listing is denied, revise your cover page to indicate that the offering is not contingent on NASDAQ approval of your listing application and that if the shares are not approved for listing, you may experience difficulty selling your shares. Ensure similar disclosure is included in your risk factor disclosure.
FirstName LastNameHoward Lee Comapany NameLucas GC Ltd February 17, 2023 Page 2 FirstName LastName Howard Lee Lucas GC Ltd February 17, 2023 Page 2 You may contact Dave Edgar, Senior Staff Accountant, at (202) 551-3459 or Christine Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding comments on the financial statements and related matters. Please contact Lauren Pierce, Staff Attorney, at (202) 551-3887 or Matthew Crispino, Staff Attorney, at (202) 551-3456 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Yang Ge
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United States securities and exchange commission logo
February 17, 2023
Howard Lee
Chief Executive Officer
Lucas GC Ltd
Room 5A01, 4th Floor
Air China Building, Xiaoyun Road
Sanyuanqiao, Chaoyang District
Beijing 100027, China
Re:Lucas GC Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted February 3, 2023
CIK No. 0001954694
Dear Howard Lee:
We have reviewed your amended draft registration statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted February 3, 2023
Cover Page
1.To the extent you intend to proceed with your offering if your NASDAQ listing is denied,
revise your cover page to indicate that the offering is not contingent
on NASDAQ approval of your listing application and that if the shares are
not approved for listing, you may experience difficulty selling your shares. Ensure similar
disclosure is included in your risk factor disclosure.
FirstName LastNameHoward Lee
Comapany NameLucas GC Ltd
February 17, 2023 Page 2
FirstName LastName
Howard Lee
Lucas GC Ltd
February 17, 2023
Page 2
You may contact Dave Edgar, Senior Staff Accountant, at (202) 551-3459 or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding comments on
the financial statements and related matters. Please contact Lauren Pierce, Staff Attorney, at
(202) 551-3887 or Matthew Crispino, Staff Attorney, at (202) 551-3456 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Yang Ge