Correspondence 0001493152-24-048458 from Basel Medical Group Ltd (BMGL)
Basel Medical Group Ltd
Date: Dec. 3, 2024 · CIK: 0002004489 · Accession: 0001493152-24-048458
AI Filing Summary & Sentiment
File numbers found in text: 333-282096
Referenced dates: November 27, 2024
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Basel
Medical Group Ltd
6
Napier Road,
Unit
#02-10/11 Gleneagles Medical Centre
Singapore
258499
Date:
December 3, 2024
Via
EDGAR
Division
of Corporation Finance
Office
of Energy & Transportation
U.S.
Securities and Exchange Commission
Washington,
D.C. 20549
Attn.:
Nudrat
Salik
Michael
Fay
Robert
Augustin
Jane
Park
Re:
Basel
Medical Group Ltd
Amendment
No. 2 to Registration Statement on Form F-1
Filed
November 14, 2024
File
No. 333-282096
Ladies
and Gentlemen:
Basel
Medical Group Ltd (the “Company”) hereby submits to the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “Commission”) this letter setting forth responses to the comments contained in the Staff’s
letter dated November 27, 2024 on the Company’s Registration Statement on Form F-1 previously filed on November 14, 2024.
Concurrently
with the filing of this letter, the Company is publicly amending and refiling its registration statement on Form F-1 (the “Registration
Statement”) with the Commission.
The
Staff’s comments are repeated below in bold and are followed by our responses. We have included page references in the Registration
Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the
meanings set forth in the Registration Statement.
Amendment
No. 2 to Form F-1 filed November 14, 2024
Selling
Shareholders, page 3
1.
We
refer to your selling shareholder table on page Alt-3. Please revise your disclosure to provide additional details regarding the transaction
in which the selling shareholders acquired their shares, including the date on which the transaction was completed and the material terms
of the agreements relating to such transaction. Please file the agreements as exhibits to the registration statement or tell us why you
believe you are not required to do so. Refer to Item 601(b)(10) of Regulation S-K.
Response:
Please refer to the revised disclosure in the section titled “Selling Shareholders”. The Company submits to the Staff that
the acquisition agreements through which such Selling Shareholders acquired their shares from Rainforest Capital VCC are not material
contracts falling within the definition of such as defined in Item 601(b)(10) of Regulation S-K, as they are primarily contracts of sale
and purchase between a selling shareholder and each acquiror to sell and purchase shares of the registrant, are not contracts material
to the registrant or its subsidiaries, and create no material obligations on the registrant or its subsidiaries.
Kindly
address any comments or questions that you have concerning the Registration Statement to our attorneys Benjamin Tan Esq. and Martryn
Mak Esq. of Sichenzia Ross Ference Carmel LLP at (646) 810-0609 or btan@srfc.law and (646) 963-6393 or mmak@srfc.law.
Thank
you for your time and attention.
Very
truly yours,
For
and on behalf of
Basel
Medical Group Ltd
/s/
Raymond Wai Man Cheung
Name:
Raymond
Wai Man Cheung
Position:
Chief
Executive Officer