SEC Comment Letter 0000000000-23-009526 to Mobile-health Network Solutions (MNDR)
Mobile-health Network Solutions
Date: Aug. 29, 2023 · CIK: 0001976695 · Accession: 0000000000-23-009526
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United States securities and exchange commission logo
August 29, 2023
Siaw Tung Yeng
Chief Executive Officer
Mobile-health Network Solutions
2 Venture Drive, #07-06/07 Vision Exchange
Singapore 608526
Re:Mobile-health Network Solutions
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted August 17, 2023
File No. 377-06781
Dear Siaw Tung Yeng:
We have reviewed your amended draft registration statement 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 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 comments apply 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 these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
August 9, 2023 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
48
1.We note your response to our prior comment 7. Please amend your disclosure to include
the descriptions provided in your response. Your revised disclosure should clearly define
any key metrics, explain how they are used, and describe the formulas for calculating
them.
Exhibits
2.We note your response to our prior comment 4. The Medical Services Agreement with
FirstName LastNameSiaw Tung Yeng
Comapany NameMobile-health Network Solutions
August 29, 2023 Page 2
FirstName LastName
Siaw Tung Yeng
Mobile-health Network Solutions
August 29, 2023
Page 2
customer A appears to be a material agreement that is required to be filed pursuant to Item
601(b)(10) of Regulation S-K. There are regulatory provisions under the federal securities
laws and other federal statutes that permit the redaction of certain confidential information
from a material agreement; however, these provisions do not permit the entire agreement
to be omitted from your public filings. Therefore, we reissue our prior comment 4.
You may contact Claire DeLabar, Senior Staff Accountant, at (202) 551-3349 or Robert
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact Austin Pattan, Staff
Attorney, at (202) 551-6756 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Meng Ding