SEC Comment Letter 0000000000-24-005959 to CASI Pharmaceuticals, Inc. (CASI) (CIK 0001962738) (CASIF)
CASI Pharmaceuticals, Inc. (CASI) (CIK 0001962738)
Date: May 22, 2024 · CIK: 0001962738 · Accession: 0000000000-24-005959
AI Filing Summary & Sentiment
File numbers found in text: 001-41666
Letter
United States securities and exchange commission logo May 22, 2024 Larry Zhang President and Principal Financial 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 Fiscal Year Ended December 31, 2023 Filed March 28, 2024 File No. 001-41666 Dear Larry Zhang: We have reviewed your filing and have the following comments. Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 20-F for Fiscal Year Ended December 31, 2023 Introduction, page 4 1.We note that you have excluded Hong Kong and Macau from your definition of "China," yet it appears that you have a Hong Kong subsidiary. In future filings, please revise to clarify that the “legal and operational” risks associated with operating in China also apply to operations in Hong Kong/Macau. This disclosure could appear in the definition itself or in an appropriate discussion of legal and operational risks. Part I Item 3. Key Information, page 7 2.In future filings, at the onset of this section, please disclose prominently that you are not a Chinese operating company but a Cayman Islands holding company with operations conducted by your subsidiaries. In addition, please provide early in this section a diagram of the company’s corporate structure.
FirstName LastNameLarry Zhang Comapany NameCASI Pharmaceuticals, Inc. May 22, 2024 Page 2 FirstName LastName Larry Zhang CASI Pharmaceuticals, Inc. May 22, 2024 Page 2 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 Daniel Crawford at 202-551-7767 or Jason Drory at 202-551-8342 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences
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United States securities and exchange commission logo
May 22, 2024
Larry Zhang
President and Principal Financial 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 Fiscal Year Ended December 31, 2023
Filed March 28, 2024
File No. 001-41666
Dear Larry Zhang:
We have reviewed your filing and have the following comments.
Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2023
Introduction, page 4
1.We note that you have excluded Hong Kong and Macau from your definition of "China,"
yet it appears that you have a Hong Kong subsidiary. In future filings, please revise to
clarify that the “legal and operational” risks associated with operating in China also apply
to operations in Hong Kong/Macau. This disclosure could appear in the definition itself or
in an appropriate discussion of legal and operational risks.
Part I
Item 3. Key Information, page 7
2.In future filings, at the onset of this section, please disclose prominently that you are not a
Chinese operating company but a Cayman Islands holding company with operations
conducted by your subsidiaries. In addition, please provide early in this section a diagram
of the company’s corporate structure.
FirstName LastNameLarry Zhang
Comapany NameCASI Pharmaceuticals, Inc.
May 22, 2024 Page 2
FirstName LastName
Larry Zhang
CASI Pharmaceuticals, Inc.
May 22, 2024
Page 2
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 Daniel Crawford at 202-551-7767 or Jason Drory at 202-551-8342 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences