SEC Comment Letter 0000000000-23-014181 to Cuprina Holdings (Cayman) LTD (CUPR)
Cuprina Holdings (Cayman) LTD
Date: Dec. 28, 2023 · CIK: 0001995704 · Accession: 0000000000-23-014181
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo December 28, 2023 David Quek Yong Qi Chief Executive Officer Cuprina Holdings (Cayman) Limited Blk 1090 Lower Delta Road #06-08 Singapore 169201 Re:Cuprina Holdings (Cayman) Limited Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted December 18, 2023 CIK No. 0001995704 Dear David Quek Yong Qi: 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. Amendment No. 2 to Draft Registration Statement on Form F-1 Prospectus Summary Corporate History and Structure, page 7 1.We note your response to prior comment two and your disclosure on page 48 that you intend to use 4.9% of the offering proceeds for loan repayment to one of your ultimate beneficial shareholders. Please clarify if this loan repayment to your ultimate beneficial shareholder is for the advances received from Cuprina Holding Pte. Ltd, as referenced on page 7.
FirstName LastNameDavid Quek Yong Qi Comapany NameCuprina Holdings (Cayman) Limited December 28, 2023 Page 2 FirstName LastName David Quek Yong Qi Cuprina Holdings (Cayman) Limited December 28, 2023 Page 2 Management's Discussion and Analysis of Financial Condition and Results of Operations Key Components of Results of Operations Operating expenses, page 60 2.We note the revisions made in response to prior comment three. It is unclear to us why no payroll-related benefits or depreciation and amortization expense is attributed to your research and development activities. In this regard, your disclosure on page 94 indicates that you have three team members responsible for R&D activities. Please advise or revise your filing accordingly. Please contact Christine Torney at 202-551-3652 or Angela Connell at 202-551-3426 if you have questions regarding comments on the financial statements and related matters. Please contact Doris Stacey Gama at 202-551-3188 or Alan Campbell at 202-551-4224 with any other questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Mathew Lewis, Esq.
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United States securities and exchange commission logo
December 28, 2023
David Quek Yong Qi
Chief Executive Officer
Cuprina Holdings (Cayman) Limited
Blk 1090 Lower Delta Road #06-08
Singapore 169201
Re:Cuprina Holdings (Cayman) Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted December 18, 2023
CIK No. 0001995704
Dear David Quek Yong Qi:
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.
Amendment No. 2 to Draft Registration Statement on Form F-1
Prospectus Summary
Corporate History and Structure, page 7
1.We note your response to prior comment two and your disclosure on page 48 that you
intend to use 4.9% of the offering proceeds for loan repayment to one of your ultimate
beneficial shareholders. Please clarify if this loan repayment to your ultimate beneficial
shareholder is for the advances received from Cuprina Holding Pte. Ltd, as referenced on
page 7.
FirstName LastNameDavid Quek Yong Qi
Comapany NameCuprina Holdings (Cayman) Limited
December 28, 2023 Page 2
FirstName LastName
David Quek Yong Qi
Cuprina Holdings (Cayman) Limited
December 28, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Key Components of Results of Operations
Operating expenses, page 60
2.We note the revisions made in response to prior comment three. It is unclear to us why no
payroll-related benefits or depreciation and amortization expense is attributed to your
research and development activities. In this regard, your disclosure on page 94 indicates
that you have three team members responsible for R&D activities. Please advise or revise
your filing accordingly.
Please contact Christine Torney at 202-551-3652 or Angela Connell at 202-551-3426 if
you have questions regarding comments on the financial statements and related matters. Please
contact Doris Stacey Gama at 202-551-3188 or Alan Campbell at 202-551-4224 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Mathew Lewis, Esq.