SEC Comment Letter 0000000000-23-011956 to Lucas GC Ltd (LGCL)
Lucas GC Ltd
Date: Nov. 1, 2023 · CIK: 0001954694 · Accession: 0000000000-23-011956
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-270107
Referenced dates: December 23, 2022
Letter
United States securities and exchange commission logo November 1, 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. 4 to Registration Statement on Form F-1 Filed October 27, 2023 File No. 333-270107 Dear Howard Lee: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Amendment No. 4 to Form F-1 filed October 27, 2023 Consolidated Financial Statements Note 2. Summary of significant accounting policies (d) Convenience translation, page F-9 1.We note that your convenience translation is based on the rate as of December 31, 2022. Please revise to apply the exchange rate as of the most recent balance sheet date included in the filing, June 30, 2023, or as of the most recent date practicable, if materially different. Refer to Rule 3-20 (b)(1) of Regulation S-X and prior comment 29 of our comment letter dated December 23, 2022.
FirstName LastNameHoward Lee Comapany NameLucas GC Ltd November 1, 2023 Page 2 FirstName LastName Howard Lee Lucas GC Ltd November 1, 2023 Page 2 Unaudited Condensed Consolidated Financial Statements Note 14. Subsequent events, page F-53 2.Please revise to disclose the specific date through which you evaluated subsequent events. Refer to ASC 855-10-50-1(a) and to prior comment 37 of our comment letter dated December 23, 2022. Please contact Dave Edgar at 202-551-3459 or Chris Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters. Please contact Lauren Pierce at 202-551-3887 or Matthew Crispino 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
November 1, 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. 4 to Registration Statement on Form F-1
Filed October 27, 2023
File No. 333-270107
Dear Howard Lee:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Amendment No. 4 to Form F-1 filed October 27, 2023
Consolidated Financial Statements
Note 2. Summary of significant accounting policies
(d) Convenience translation, page F-9
1.We note that your convenience translation is based on the rate as of December 31,
2022. Please revise to apply the exchange rate as of the most recent balance sheet date
included in the filing, June 30, 2023, or as of the most recent date practicable, if materially
different. Refer to Rule 3-20 (b)(1) of Regulation S-X and prior comment 29 of our
comment letter dated December 23, 2022.
FirstName LastNameHoward Lee
Comapany NameLucas GC Ltd
November 1, 2023 Page 2
FirstName LastName
Howard Lee
Lucas GC Ltd
November 1, 2023
Page 2
Unaudited Condensed Consolidated Financial Statements
Note 14. Subsequent events, page F-53
2.Please revise to disclose the specific date through which you evaluated subsequent events.
Refer to ASC 855-10-50-1(a) and to prior comment 37 of our comment letter dated
December 23, 2022.
Please contact Dave Edgar at 202-551-3459 or Chris Dietz at 202-551-3408 if you have
questions regarding comments on the financial statements and related matters. Please contact
Lauren Pierce at 202-551-3887 or Matthew Crispino at 202-551-3456 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Yang Ge