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SEC Comment Letter 0000000000-23-008818 to CASI Pharmaceuticals, Inc. (CASI) (CIK 0001962738) (CASIF)

CASI Pharmaceuticals, Inc. (CASI) (CIK 0001962738)
Date: Aug. 14, 2023 · CIK: 0001962738 · Accession: 0000000000-23-008818

AI Filing Summary & Sentiment

File numbers found in text: 001-41666

Date
August 14, 2023
Author
Not clearly detected
Form
UPLOAD
Company
CASI Pharmaceuticals, Inc. (CASI) (CIK 0001962738)

Letter

United States securities and exchange commission logo August 14, 2023 Wei-Wu He Chief Executive Officer CASI Pharmaceuticals, Inc. 1701-1702, China Central Office Tower 1 No. 81 Jianguo Road Chaoyang District Beijing, 100025 People’s Republic of China Re:CASI Pharmaceuticals, Inc. Form 20-F for the Fiscal Year December 31, 2022 File No. 001-41666 Dear Wei-Wu He: We have limited our review of your filing to the submission and/or disclosures as required by Item 16I of Form 20-F and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. After reviewing your response to these comments, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 98 1.We note your statement that you reviewed your register of members and public filings made by your shareholders in connection with your required submission under paragraph (a). Please supplementally describe any additional materials that were reviewed and tell us whether you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission. In your response, please provide a similarly detailed discussion of the materials reviewed and legal opinions or third party certifications relied upon in connection with the required disclosures under paragraphs (b)(2) and (3). 2.In order to clarify the scope of your review, please supplementally describe the steps you have taken to confirm that none of the members of your board or the boards of your consolidated foreign operating entities are officials of the Chinese Communist Party. For

FirstName LastNameWei-Wu He Comapany NameCASI Pharmaceuticals, Inc. August 14, 2023 Page 2 FirstName LastName Wei-Wu He CASI Pharmaceuticals, Inc. August 14, 2023 Page 2 instance, please tell us how the board members’ current or prior memberships on, or affiliations with, committees of the Chinese Communist Party factored into your determination. In addition, please tell us whether you have relied upon third party certifications such as affidavits as the basis for your disclosure. 3.We note that your disclosures pursuant to Items 16I(b)(3) and (b)(5) are provided for “CASI Pharmaceuticals, Inc.” Please note that Item 16I(b) requires that you provide disclosures for yourself and your consolidated foreign operating entities. With respect to (b)(3) and (b)(5) please provide the required information for you and all of your consolidated foreign operating entities in your supplemental response. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Austin Pattan at (202) 551-6756 or Christopher Dunham at (202) 551- 3783 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Peter Huang

Show Raw Text
United States securities and exchange commission logo
August 14, 2023
Wei-Wu He
Chief Executive Officer
CASI Pharmaceuticals, Inc.
1701-1702, China Central Office Tower 1
No. 81 Jianguo Road Chaoyang District
Beijing, 100025
People’s Republic of China
Re:CASI Pharmaceuticals, Inc.
Form 20-F for the Fiscal Year December 31, 2022
File No. 001-41666
Dear Wei-Wu He:
            We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F and have the following comments. In some of our comments,
we may ask you to provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 98
1.We note your statement that you reviewed your register of members and public filings
made by your shareholders in connection with your required submission under paragraph
(a).  Please supplementally describe any additional materials that were reviewed and tell
us whether you relied upon any legal opinions or third party certifications such as
affidavits as the basis for your submission.  In your response, please provide a similarly
detailed discussion of the materials reviewed and legal opinions or third party
certifications relied upon in connection with the required disclosures under paragraphs
(b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party.  For

 FirstName LastNameWei-Wu He
 Comapany NameCASI Pharmaceuticals, Inc.
 August 14, 2023 Page 2
 FirstName LastName
Wei-Wu He
CASI Pharmaceuticals, Inc.
August 14, 2023
Page 2
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination.  In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
3.We note that your disclosures pursuant to Items 16I(b)(3) and (b)(5) are provided for
“CASI Pharmaceuticals, Inc.”  Please note that Item 16I(b) requires that you provide
disclosures for yourself and your consolidated foreign operating entities.  With respect to
(b)(3) and (b)(5) please provide the required information for you and all of your
consolidated foreign operating entities in your supplemental response.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Austin Pattan at (202) 551-6756 or Christopher Dunham at (202) 551-
3783 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Peter Huang