SEC Comment Letter 0000000000-24-007087 to Anbio Biotechnology (NNNN) (CIK 0001982708) (NNNN)
Anbio Biotechnology (NNNN) (CIK 0001982708)
Date: June 21, 2024 · CIK: 0001982708 · Accession: 0000000000-24-007087
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United States securities and exchange commission logo June 21, 2024 Michael Lau Chief Executive Officer Anbio Biotechnology Friedrich-Ebert-Anlage 49, 60308 Frankfurt am Main Germany Re:Anbio Biotechnology Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted June 10, 2024 CIK No. 0001982708 Dear Michael Lau: We have reviewed your amended draft registration statement and have the following comments. 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 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 the information you provide in response to this letter and your amended draft registration statement or filed registration statement, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our March 22, 2024 letter. Amendment No. 2 to Draft Registration Statement on Form S-1, Submitted June 10, 2024 Our Strategies Expand Market Share in the Diagnostic and Biotechnology Sectors, page 48 1.We note your revised disclosure that, for the fiscal year ended December 31, 2023, you recognized 40% of your total revenue from non-COVID-19 related products. Please further revise your disclosure to clarify the main categories of non-COVID-19 related products that contributed to your revenue. Refer to Item 4.a of Form F-1 and Item 4.B.1 of Form 20-F.
FirstName LastNameMichael Lau Comapany NameAnbio Biotechnology June 21, 2024 Page 2 FirstName LastName Michael Lau Anbio Biotechnology June 21, 2024 Page 2 Our Products, page 50 2.We note your response to prior comment 13, including your disclosure that you have commenced sales of your non-COVID products and your disclosure that "[t]he IVDR approval process would have no bearing with respect to the sales of [y]our non-COVID products." However, we also note your disclosure on page 52 that you "are currently preparing the documentation for the IVDR registration of [y]our non-COVID-19 IVD products" and that you "anticipate IVDR approval by December 31, 2026." Please further revise your disclosure to clarify the purpose and significance of the IVDR registration on your non-COVID products if the approval process has no bearing with respect to the sales of such products. Executive Compensation Compensation of Directors, page 76 3.We note your response to prior comment 21. Please also update your director compensation disclosures for the fiscal year ended December 31, 2023. Refer to Item 4.a of Form F-1 and Item 6.B. of part I of Form 20-F. Please contact Sasha Parikh at 202-551-3627 or Daniel Gordon at 202-551-3486 if you have questions regarding comments on the financial statements and related matters. Please contact Jessica Dickerson at 202-551-8013 or Tim Buchmiller at 202-551-3635 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: William S. Rosenstadt, Esq.
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United States securities and exchange commission logo
June 21, 2024
Michael Lau
Chief Executive Officer
Anbio Biotechnology
Friedrich-Ebert-Anlage 49, 60308
Frankfurt am Main
Germany
Re:Anbio Biotechnology
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted June 10, 2024
CIK No. 0001982708
Dear Michael Lau:
We have reviewed your amended draft registration statement and have the following
comments.
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 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
March 22, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form S-1, Submitted June 10, 2024
Our Strategies
Expand Market Share in the Diagnostic and Biotechnology Sectors, page 48
1.We note your revised disclosure that, for the fiscal year ended December 31, 2023, you
recognized 40% of your total revenue from non-COVID-19 related products. Please
further revise your disclosure to clarify the main categories of non-COVID-19 related
products that contributed to your revenue. Refer to Item 4.a of Form F-1 and Item 4.B.1 of
Form 20-F.
FirstName LastNameMichael Lau
Comapany NameAnbio Biotechnology
June 21, 2024 Page 2
FirstName LastName
Michael Lau
Anbio Biotechnology
June 21, 2024
Page 2
Our Products, page 50
2.We note your response to prior comment 13, including your disclosure that you have
commenced sales of your non-COVID products and your disclosure that "[t]he IVDR
approval process would have no bearing with respect to the sales of [y]our non-COVID
products." However, we also note your disclosure on page 52 that you "are currently
preparing the documentation for the IVDR registration of [y]our non-COVID-19 IVD
products" and that you "anticipate IVDR approval by December 31, 2026." Please further
revise your disclosure to clarify the purpose and significance of the IVDR registration on
your non-COVID products if the approval process has no bearing with respect to the sales
of such products.
Executive Compensation
Compensation of Directors, page 76
3.We note your response to prior comment 21. Please also update your director
compensation disclosures for the fiscal year ended December 31, 2023. Refer to Item 4.a
of Form F-1 and Item 6.B. of part I of Form 20-F.
Please contact Sasha Parikh at 202-551-3627 or Daniel Gordon at 202-551-3486 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jessica Dickerson at 202-551-8013 or Tim Buchmiller at 202-551-3635 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: William S. Rosenstadt, Esq.