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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

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 29, 2023
Author
Office of Technology
Form
UPLOAD
Company
Mobile-health Network Solutions

Letter

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 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

Show Raw Text
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