SEC Comment Letter 0000000000-24-012475 to Cellyan Biotechnology Co., Ltd (HKPD)
Cellyan Biotechnology Co., Ltd
Date: Nov. 8, 2024 · CIK: 0002007702 · Accession: 0000000000-24-012475
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-282876
Letter
November 8, 2024 Lap Sun Wong Chief Executive Officer and Chairman of the Board Hong Kong Pharma Digital Technology Holdings Ltd Room B1, 5/F., Well Town Industrial Building 13 Ko Fai Road, Yau Tong, Kowloon Hong Kong Re:Hong Kong Pharma Digital Technology Holdings Ltd Registration Statement on Form F-1 Filed October 29, 2024 File No. 333-282876 Dear Lap Sun Wong: We have reviewed your registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Registration Statement on Form F-1 Dilution, page 52 1.You disclose that your pro forma net tangible book value as of March 31, 2024 would have been $4,178,515. Please provide us with your calculation of this amount. Principal and Selling Shareholders, page 96 2.Please revise to disclose the nature of any position, office, or other material relationship which any selling shareholder and/or the persons who have control over the selling shareholders have had within the past three years with the registrant or any of its predecessors or affiliates. Refer to Item 507 of Regulation S-K.
November 8, 2024 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Nasreen Mohammed at 202-551-3773 or Suying Li at 202-551-3335 if you have questions regarding comments on the financial statements and related matters. Please contact Rucha Pandit at 202-551-6022 or Mara Ransom at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Kevin Sun
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November 8, 2024
Lap Sun Wong
Chief Executive Officer and Chairman of the Board
Hong Kong Pharma Digital Technology Holdings Ltd
Room B1, 5/F., Well Town Industrial Building
13 Ko Fai Road, Yau Tong, Kowloon
Hong Kong
Re:Hong Kong Pharma Digital Technology Holdings Ltd
Registration Statement on Form F-1
Filed October 29, 2024
File No. 333-282876
Dear Lap Sun Wong:
We have reviewed your registration statement and have the following comment(s).
Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1
Dilution, page 52
1.You disclose that your pro forma net tangible book value as of March 31, 2024 would
have been $4,178,515. Please provide us with your calculation of this amount.
Principal and Selling Shareholders, page 96
2.Please revise to disclose the nature of any position, office, or other material
relationship which any selling shareholder and/or the persons who have control over
the selling shareholders have had within the past three years with the registrant or any
of its predecessors or affiliates. Refer to Item 507 of Regulation S-K.
November 8, 2024
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Nasreen Mohammed at 202-551-3773 or Suying Li at 202-551-3335 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rucha Pandit at 202-551-6022 or Mara Ransom at 202-551-3264 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Kevin Sun