SEC Comment Letter for ANEW HEALTH Ltd (CIK 0002019042) — Apr 4, 2025
ANEW HEALTH Ltd (CIK 0002019042)
Date: April 4, 2025 · CIK: 0002019042 · Accession: 0000000000-25-003640
AI Filing Summary & Sentiment
File numbers found in text: 333-285657
Letter
April 4, 2025 Ka Wai Victor Mo Chief Executive Officer ANEW Health Limited Unit 2301-05, 23/F, Tower 5, The Gateway Harbour City, 15 Canton Road Tsim Sha Tsui, Kowloon, Hong Kong Re:ANEW Health Limited Amendment No. 1 to Registration Statement on Form F-1 Filed March 31, 2025 File No. 333-285657 Dear Ka Wai Victor Mo: We have reviewed your amended registration statement and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our March 18, 2025 letter. Form F-1/A filed March 31, 2025 Note 2 - Summary of Significant Accounting Policies Revenue Recognition, page F-35 1.We note your response to prior comment 2. Please tell us what consideration you gave to presenting disaggregated revenue by group of similar products and services within your financial statement footnotes as prescribed by ASC 280-10-50-40, similar to the presentation in your results of operations discussion on page 64. See also guidance for disaggregated revenue presentation in ASC 606-10-50-5. Please contact Tayyaba Shafique at 202-551-2110 or Terence O'Brien at 202-551- 3355 if you have questions regarding comments on the financial statements and related
April 4, 2025 Page 2 matters. Please contact Conlon Danberg at 202-551-4466 or Jane Park at 202-551-7439 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc:William S. Rosenstadt, Esq.
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April 4, 2025
Ka Wai Victor Mo
Chief Executive Officer
ANEW Health Limited
Unit 2301-05, 23/F, Tower 5, The Gateway
Harbour City, 15 Canton Road
Tsim Sha Tsui, Kowloon, Hong Kong
Re:ANEW Health Limited
Amendment No. 1 to Registration Statement on Form F-1
Filed March 31, 2025
File No. 333-285657
Dear Ka Wai Victor Mo:
We have reviewed your amended registration statement and have the following
comment.
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. Unless we note
otherwise, any references to prior comments are to comments in our March 18, 2025 letter.
Form F-1/A filed March 31, 2025
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page F-35
1.We note your response to prior comment 2. Please tell us what consideration you gave
to presenting disaggregated revenue by group of similar products and services within
your financial statement footnotes as prescribed by ASC 280-10-50-40, similar to the
presentation in your results of operations discussion on page 64. See also guidance for
disaggregated revenue presentation in ASC 606-10-50-5.
Please contact Tayyaba Shafique at 202-551-2110 or Terence O'Brien at 202-551-
3355 if you have questions regarding comments on the financial statements and related
April 4, 2025
Page 2
matters. Please contact Conlon Danberg at 202-551-4466 or Jane Park at 202-551-7439 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc:William S. Rosenstadt, Esq.