Correspondence 0001104659-25-004850 from ASCENTAGE PHARMA GROUP INTERNATIONAL (AAPG)
ASCENTAGE PHARMA GROUP INTERNATIONAL
Date: Jan. 21, 2025 · CIK: 0002023311 · Accession: 0001104659-25-004850
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File numbers found in text: 333-284064
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CORRESP
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filename1.htm
J.P. Morgan Securities LLC
383 Madison Avenue
New York, New York 10179
Citigroup Global Markets Inc.
388 Greenwich Street
New York, NY 10013
As representatives of the underwriters
VIA EDGAR
January 21, 2025
Tamika Sheppard
Laura Crotty
Eric Atallah
Angela Connell
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Re: Ascentage
Pharma Group International (the “Company”)
Registration Statement on Form F-1, as
amended (File No. 333-284064)
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended
(the “Securities Act”), we, as the representatives of the several underwriters (the “Representatives”),
hereby join in the request of Ascentage Pharma Group International, an exempted company incorporated under the laws of the Cayman Islands
with limited liability (the “Company”), that the effective date of the above-referenced Registration Statement on Form F-1
be accelerated so that it will be declared effective at 3:00 p.m. Eastern Time, on January 23, 2025, or as soon thereafter
as practicable, or at such other time thereafter as the Company or its outside counsel, Wilson Sonsini Goodrich & Rosati Professional
Corporation, may request by telephone to the staff of the Securities and Exchange Commission.
Pursuant to Rule 460 under the Securities Act, we, as the Representatives,
wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers,
institutions and others prior to the requested effective time of the Registration Statement.
We, the undersigned Representatives, hereby represent that we are in
compliance and will comply, and we have been informed by the other participating underwriters that they are in compliance and will comply,
with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the offering pursuant
to the above-referenced Registration Statement and Preliminary Prospectus.
[Signature page follows]
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Very truly yours,
J.P. Morgan Securities LLC
Citigroup Global Markets Inc.
As Representatives of the several Underwriters
J.P. MORGAN SECURITIES LLC
By:
/s/ Sophie Jones
Name:
Sophie Jones
Title:
Managing Director
CITIGROUP GLOBAL MARKETS INC.
By:
/s/ Ling Zhang
Name:
Ling Zhang
Title:
Managing Director
[Signature Page to Underwriters’ Acceleration
Request Letter]