SEC Company Response from DAVION HEALTHCARE (DAVI) — Sep 26, 2025
DAVION HEALTHCARE PLC
Date: Sept. 26, 2025 · CIK: 0002039072 · Accession: 0001683168-25-007262
AI Filing Summary & Sentiment
File numbers found in text: 333-223104, 333-289205
Letter
Washington, DC 20549 Registration Statement on Form F-1 Filed August 4, 2025 File No. 333-289205
Re: Davion Healthcare Plc
Dear Messrs. Grana and Danberg,
We are in receipt of your letter dated August 31st, 2025 regarding our forementioned filing. Below please find our respective responses:
Registration Statement on Form F-1
Cover Page
1. Please revise your cover page to disclose that you are registering 25,000,000 ordinary shares, and clarify whether these ordinary shares are being registered as a secondary resale transaction. Please also advise whether the ordinary shares being registered are to be offered on a delayed or continuous basis pursuant to Rule 415 under the Securities Act, and identify each potential selling shareholder, as applicable. Your disclosure should include the number of ordinary shares held by each of the selling shareholders and the portion of those ordinary shares that may be sold pursuant to this registration statement, as well as the number of ordinary shares that may be sold in reliance on Rule 144 of the Securities Act. If no shares are being offered by the Company or by any selling shareholders, please consider whether the shares should be registered under the Exchange Act using Form 20 rather than Form F-1.
RESPONSE: We have revised our cover page to clearly state that all 25,000,000 issued and outstanding ordinary shares are being registered for resale trading on Nasdaq; said registration is “continuous” pursuant to Rule 415(a)1. Additionally, the full breakdown of all registered shareholders and number of their shares are now found within the revised F-1. All shares are being offered by individual shareholders, and neither the issuer nor subsidiary. In this Registration Statement, we have used the term “Registered Shareholders” to describe the holders of our issued and outstanding ordinary shares whose shares are being registered for potential resale pursuant to this prospectus. We note that the term “Registered Shareholders” was used in the Form F-1 registration statement of Spotify Technology S.A. (File No. 333-223104), which was declared effective by the Commission on April 3, 2018, in connection with its direct listing on the New York Stock Exchange. From a substantive standpoint, “Registered Shareholders” and “Selling Shareholders” are equivalent, as both terms identify the shareholders whose shares are being registered for resale. We have adopted the “Registered Shareholders” terminology in order to align with this established precedent for direct listings, and to make clear that no shareholder is required to sell shares and that the Company will not receive any proceeds from any resale.
2. We note your disclosure on page 3 that the anticipated opening price is $10.00 per ordinary share, and on page 61 that "the opening trading price will be determined by buy and sell orders collected by Nasdaq’s designated market maker." Please revise your cover page to disclose your opening price, and the process by which your opening price will be determined. Please also disclose your financial advisor and their role in that process. Please also revise your summary to include corresponding disclosures. We refer to your disclosure on page 61 that "in order to comply with NASDAQ Global Market listing requirements, you have appointed a FINRA- registered marketmaker to facilitate the opening of trading and to provide continuous bid and ask quotations."
RESPONSE: The cover page and “Plan of Distribution” now discloses that the opening price will be determined by Nasdaq’s auction process facilitated by the lead market maker. Management has used $10 per share solely for Nasdaq compliance purposes. We identify Revere Securities LLC as our corporate advisor and lead market maker. Additionally, disclosure is expanded to clarify that the opening price is not fixed. It will be set by Nasdaq’s auction process, managed by a FINRA-registered lead market maker. We have included and expanded these disclosures in the Summary and Plan of Distribution.
3. Please revise your cover page to disclose the duration of the offering.
RESPONSE: Our cover page now clarifies that the registration is for a direct listing, not a time-bound offering, and remains effective until withdrawn or amended by post-effective amendment.
Prospectus Summary, page 1
4. Please revise your summary to briefly discuss your current pipeline of products, including BreastCheck, FootFlow, Testic, ThermaDerm and any other products in development, emphasizing the current state of development and regulatory approvals of each. In particular, please also note the timing for commercialization and the markets in which you intend to sell each product. Please also clarify the date that each product received their regulatory approvals.
RESPONSE: The Prospectus Summary now expands and describes the four non-invasive home tests noted, (BreastCheck, FootFlow, Testic, ThermaDerm), their regulatory status (Class I devices), and launch timing (BreastCheck H1 2026 first).
5. Please revise your summary to disclose that you are a pre-revenue company that has not generated any revenue and do not expect to generate revenue until the second half of 2025 at the earliest. Please also note that during the year ended December 31, 2024, you incurred an operating loss of €1,320,353.
RESPONSE: We have revised our summary to explicitly disclose Davion is pre-revenue, incurred operating losses in 2024 and 2023, and does not expect revenues until the first half of 2026. Additionally, we have expanded the disclosure related to the Company’s funding and status as a going concern.
6. Please revise your summary to note, as you do on page 56, that certain of your directors and executive officers have agreed to a 90 day lock-up period during which they will not sell or transfer their ordinary shares. Please also revise to note the directors and executive officers that have entered into the lock-up agreement, and file the lock-up agreement as an exhibit to your registration statement.
RESPONSE: Our summary has been revised to disclose the 90-day lock-up for all six directors (Jack Kaye, David Over, Sir Eric Peacock, Kevin Riches, Susan M. King, Julian Sluyters) with lock-up BOD resolutions; and this has been filed as exhibit 99.3 Directors Lock Up Agreement signed by all Directors.
Our business and prospects depend significantly on our ability to build our product brands. . . , page 4
7. Please briefly explain your annual BreastCheck Day.
RESPONSE: Our Annual “BreastCheck Day” was purely aspirational as we were hoping to already be on the Nasdaq by early October, as it is “Breast Cancer Awareness Month”. But given the current time-lines, this phrase and wording have been entirely removed from the F-1.
Risk Factors, page 4
8. Please revise your risk factor disclosure to discuss the risk to investors stemming from your direct listing. In particular, please consider the risk to investors from increased price and market volatility, the process for the listing and setting of the opening trading price of your ordinary shares, the lack of safeguards associated with a traditional underwritten offering, that the opening trading price of your ordinary shares may not be related to historical sales prices, uncertainty associated with the fact that few companies have undertaken direct listings to date, and the challenges the tracing requirement could pose for potential shareholders in relation to securities liability claims under Section 1 1 and Section 1 2 of the Securities Act for a direct listing versus a traditional IPO.
RESPONSE: Our risk factors have been expanded to cover direct listing risks: potential volatility, lack of underwriter safeguards, pricing disconnects, limited precedent, tracing difficulties under Sections 11 and 12.
We could experience cost increases or disruptions in supply of raw materials or other components used in BreastCheck, page 4.
9. We note your disclosure that your manufacturer of BreastCheck could incur significant costs related to procuring raw materials required to manufacture and assemble BreastCheck," and that various raw materials are used in the manufacture of BreastCheck. Please revise to disclose these raw materials and their source. Please also revise to identify NeuRX Health Inc as the manufacturer and distributor of BreastCheck, as you do on page 28 .
You may face difficulties in protecting your interests, and your ability to protect your rights through U. S. courts may be limited. . . , page 1 1
RESPONSE: Risk factor disclosure now names NeuRX Health Inc. of Rhode Island as exclusive manufacturer/distributor of BreastCheck, and describes raw materials such as liquid crystal film, adhesives, housings and they are sourced by U.S. based suppliers.
10. We note your disclosure that certain corporate governance practices in Ireland, which is your home country, differ significantly from requirements for companies incorporated in other jurisdictions such as the United States. Currently, you do not plan to rely on home country practice with respect to any corporate governance matter. However, on page 12, you note that because you are a foreign private issuer under the Exchange Act, you are exempt from certain provisions of the securities rules and regulations in the United States that are applicable to U.S. domestic issuers. Please reconcile these disclosures, and advise whether you will be relying on Irish home country practice pursuant to the foreign private issuer exemptions.
RESPONSE: Disclosure have been revised to clarify that the Company is a foreign private issuer which, while eligible for exemptions, has overtly stated that it does not intend to rely on Irish home-country practices inconsistent with Nasdaq corporate governance standards.
Expenses of Issuance and Distribution, page 1
11. Please explain the source of funds that will be used to pay the estimated $871,900 of expenses in connection with the registration of your shares given that you have never generated revenue, have de minimis cash on hand and will not receive any proceeds from the registration of your shares in a direct listing.
RESPONSE: Expenses table provided showing $871,900 total, funded through non-interest-bearing advances from Malbrite Ltd. (owned by CEO Jack Kaye), repayable only upon a capital raise. Note, we have expanded our disclosures to address related party nature of the funding commitment by the CEO.
Capitalization, page 1 5
12. We note the cash and cash equivalents balance presented within Capitalization uses amounts as of December 31, 2023 . Please update for consistency with December 31, 2024 balances.
RESPONSE: Our capitalization table has been revised to December 2024 balances, and not 2023.
Corporate History And Structure, page 1 6
13. We note that Davion Healthcare Plc. (Cyprus) issued 12,258,458 ordinary shares in 2022, along with a further 7,741,542 ordinary shares in 2024 and an additional 5,000,000 ordinary shares in 2024. Please disclose the price at which these ordinary shares were sold and briefly discuss the nature of each of these transactions, including whether they were transactions exempt from registration under the Securities Act. Please also revise your risk factor disclosures, as applicable, to note that recent sales prices for your ordinary shares may bear little or no relation to the trading price at or subsequent to the opening of trading of the ordinary shares on Nasdaq.
RESPONSE: Our corporate history has been expanded: Cyprus issuances in 2022–2024 were all at par (€0.01) in connection with capitalization and IP transfers and were exempt private transactions not subject to the U.S. Securities Act. Additionally, we have referenced that the public share price my bear little or not relation to recent private sales within the risk factor disclosures.
Management’s Discussion And Analysis Of Consolidated Financial Condition And Results Of Operations
Overview of Business Operations, page 23
14. We note your disclosure on page 24 that "it can only be assumed that there is a large and open market of women who would wish to monitor their health in the privacy of their own home, particularly given that the accuracy level [ of BreastCheck] is the same as a mammogram." Please substantiate your claim that BreastCheck has the same accuracy level as a mammogram.
RESPONSE: Reference to BreastCheck accuracy level versus mammogram removed; disclosure revised to avoid unsubstantiated equivalence claims.
Operating Results, page 27
15. Please provide a more detailed discussion of the material factors impacting the decrease in expenses, and trends management expects in upcoming periods. Please discuss any material events and uncertainties that would cause reported financial information not to be necessarily indicative of future operating results or of future financial condition. As a pre-revenue company focusing on research and development, please also provide a breakdown of your research and development by product, by function of costs (e. g. clinical, regulatory application), or by nature of costs (e.g. payroll, outsourcing consultant). Refer to Item 5.A of Form 20-F.
RESPONSE: Our MD&A is now expanded to discuss drivers of expense trends, R&D allocations (clinical, regulatory, outsourcing), and uncertainties impacting forward-looking results.
16. Please revise to explain the decline in your research and development expenses during the comparative period.
RESPONSE: Decline in R&D expenses explained as due to reduced external development activity after products reached near-final stage.
17. We note your disclosure on page 28 that "the Company secured a significant agreement with NeuRX Health Inc of Rhode Island, USA, [ during the year ending December 31, 2024] for the manufacturing and distribution of BreastCheck,"and that "the agreement will provide a steady revenue stream in the form of payments and annual royalties based on product manufacturing and distribution volumes." We also note that an outline agreement was filed with NeuRX Health as Exhibit 10.2 to the registration statement. Please revise to disclose the material terms of your agreement with NeuRX Health, including payments and annual royalties due under the agreement. Please also advise if a final agreement has been entered into with NeuRX, and if so, file such agreement as an exhibit to your registration statement. Refer to Item 10.C of Form 20-F.
RESPONSE: Material terms of NeuRX Health agreement have now been added, including royalty-based payments tied to manufacturing/distribution volumes. Final executed agreement is now listed as an exhibit.
Liquidity and Capital Resources, page 28
18. We note your disclosure regarding the Company's reliance on the personal financial support of the Chief Executive Officer, who has provided all funding to date. We also note on page 52 you state that the financial support is provided through Malbrite Ltd. , a Company owned by Jack Kaye.
• Please reconcile and expand your disclosures to provide information on material terms of any agreement between the Company and the provider of financial support.
• We note that Malbrite Ltd. is not listed as an affiliate shareholder on page 52, so it is not clear how the Company is settling any liabilities from the financial support it receiv
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CORRESP
1
filename1.htm
The Cube Building, Monahan Rd
Cork, T12 H1XY, Ireland
September 26th, 2025
US Securities & Exchange Commission
Corporate Finance Division
Washington, DC 20549
Re: Davion Healthcare Plc
Registration Statement on Form F-1 Filed August
4, 2025
File No. 333-289205
Dear Messrs. Grana and Danberg,
We are in receipt of your
letter dated August 31st, 2025 regarding our forementioned filing. Below please find our respective responses:
Registration Statement on Form F-1
Cover Page
1. Please revise your cover page to disclose that you are registering
25,000,000 ordinary shares, and clarify whether these ordinary shares are being registered as a secondary resale transaction. Please
also advise whether the ordinary shares being registered are to be offered on a delayed or continuous basis pursuant to Rule 415 under
the Securities Act, and identify each potential selling shareholder, as applicable. Your disclosure should include the number of ordinary
shares held by each of the selling shareholders and the portion of those ordinary shares that may be sold pursuant to this registration
statement, as well as the number of ordinary shares that may be sold in reliance on Rule 144 of the Securities Act. If no shares are
being offered by the Company or by any selling shareholders, please consider whether the shares should be registered under the Exchange
Act using Form 20 rather than Form F-1.
RESPONSE: We have revised our cover page to
clearly state that all 25,000,000 issued and outstanding ordinary shares are being registered for resale trading on Nasdaq; said registration
is “continuous” pursuant to Rule 415(a)1. Additionally, the full breakdown of all registered shareholders and number of their
shares are now found within the revised F-1. All shares are being offered by individual shareholders, and neither the issuer nor
subsidiary. In this Registration Statement, we have used the term “Registered Shareholders” to describe the holders of our
issued and outstanding ordinary shares whose shares are being registered for potential resale pursuant to this prospectus. We note that
the term “Registered Shareholders” was used in the Form F-1 registration statement of Spotify Technology S.A. (File No. 333-223104),
which was declared effective by the Commission on April 3, 2018, in connection with its direct listing on the New York Stock Exchange.
From a substantive standpoint, “Registered Shareholders” and “Selling Shareholders” are equivalent, as both terms
identify the shareholders whose shares are being registered for resale. We have adopted the “Registered Shareholders” terminology
in order to align with this established precedent for direct listings, and to make clear that no shareholder is required to sell shares
and that the Company will not receive any proceeds from any resale.
1
2. We note your disclosure on page 3 that the anticipated opening
price is $10.00 per ordinary share, and on page 61 that "the opening trading price will be determined by buy and sell orders
collected by Nasdaq’s designated market maker." Please revise your cover page to disclose your opening price, and the process by
which your opening price will be determined. Please also disclose your financial advisor and their role in that process. Please also
revise your summary to include corresponding disclosures. We refer to your disclosure on page 61 that "in order to comply with NASDAQ
Global Market listing requirements, you have appointed a FINRA- registered marketmaker to facilitate the opening of trading and to provide
continuous bid and ask quotations."
RESPONSE: The cover page and “Plan
of Distribution” now discloses that the opening price will be determined by Nasdaq’s auction process facilitated by the lead
market maker. Management has used $10 per share solely for Nasdaq compliance purposes. We identify Revere Securities LLC as our corporate
advisor and lead market maker. Additionally, disclosure is expanded to clarify that the opening price is not fixed. It will be set by
Nasdaq’s auction process, managed by a FINRA-registered lead market maker. We have included and expanded these disclosures in the
Summary and Plan of Distribution.
3. Please revise your cover page to disclose the duration of the
offering.
RESPONSE: Our cover page now clarifies
that the registration is for a direct listing, not a time-bound offering, and remains effective until withdrawn or amended by post-effective
amendment.
Prospectus
Summary, page 1
4. Please revise your summary to briefly discuss your current pipeline
of products, including BreastCheck, FootFlow, Testic, ThermaDerm and any other products in development, emphasizing the current state
of development and regulatory approvals of each. In particular, please also note the timing for commercialization and the markets in
which you intend to sell each product. Please also clarify the date that each product received their regulatory approvals.
RESPONSE: The Prospectus Summary now expands and describes
the four non-invasive home tests noted, (BreastCheck, FootFlow, Testic, ThermaDerm), their regulatory status (Class I devices), and launch
timing (BreastCheck H1 2026 first).
5. Please revise your summary to disclose that you are a pre-revenue
company that has not generated any revenue and do not expect to generate revenue until the second half of 2025 at the earliest. Please
also note that during the year ended December 31, 2024, you incurred an operating loss of €1,320,353.
RESPONSE: We have revised our summary to explicitly disclose
Davion is pre-revenue, incurred operating losses in 2024 and 2023, and does not expect revenues until the first half of 2026. Additionally,
we have expanded the disclosure related to the Company’s funding and status as a going concern.
6. Please revise your summary to note, as you do on page 56, that
certain of your directors and executive officers have agreed to a 90 day lock-up period during which they will not sell or transfer their
ordinary shares. Please also revise to note the directors and executive officers that have entered into the lock-up agreement, and file
the lock-up agreement as an exhibit to your registration statement.
RESPONSE: Our summary has been revised
to disclose the 90-day lock-up for all six directors (Jack Kaye, David Over, Sir Eric Peacock, Kevin Riches, Susan M. King, Julian Sluyters)
with lock-up BOD resolutions; and this has been filed as exhibit 99.3 Directors Lock Up Agreement signed by all Directors.
Our business and prospects
depend significantly on our ability to build our product brands. . . , page 4
7. Please briefly explain your annual BreastCheck Day.
RESPONSE: Our Annual “BreastCheck
Day” was purely aspirational as we were hoping to already be on the Nasdaq by early October, as it is “Breast Cancer Awareness
Month”. But given the current time-lines, this phrase and wording have been entirely removed from the F-1.
2
Risk Factors,
page 4
8. Please revise your risk factor disclosure to discuss the risk
to investors stemming from your direct listing. In particular, please consider the risk to investors from increased price and market
volatility, the process for the listing and setting of the opening trading price of your ordinary shares, the lack of safeguards associated
with a traditional underwritten offering, that the opening trading price of your ordinary shares may not be related to historical sales
prices, uncertainty associated with the fact that few companies have undertaken direct listings to date, and the challenges the tracing
requirement could pose for potential shareholders in relation to securities liability claims under Section 1 1 and Section 1 2 of the
Securities Act for a direct listing versus a traditional IPO.
RESPONSE: Our risk factors have been
expanded to cover direct listing risks: potential volatility, lack of underwriter safeguards, pricing disconnects, limited precedent,
tracing difficulties under Sections 11 and 12.
We could experience cost increases
or disruptions in supply of raw materials or other components used in BreastCheck, page 4.
9. We note your disclosure that your manufacturer of BreastCheck
could incur significant costs related to procuring raw materials required to manufacture and assemble BreastCheck," and that various
raw materials are used in the manufacture of BreastCheck. Please revise to disclose these raw materials and their source. Please also
revise to identify NeuRX Health Inc as the manufacturer and distributor of BreastCheck, as you do on page 28 .
You may face difficulties in protecting
your interests, and your ability to protect your rights through U. S. courts may be limited. . . , page 1 1
RESPONSE: Risk factor disclosure now names
NeuRX Health Inc. of Rhode Island as exclusive manufacturer/distributor of BreastCheck, and describes raw materials such as liquid crystal
film, adhesives, housings and they are sourced by U.S. based suppliers.
10. We note your disclosure that certain corporate governance practices
in Ireland, which is your home country, differ significantly from requirements for companies incorporated in other jurisdictions such
as the United States. Currently, you do not plan to rely on home country practice with respect to any corporate governance matter. However,
on page 12, you note that because you are a foreign private issuer under the Exchange Act, you are exempt from certain provisions of
the securities rules and regulations in the United States that are applicable to U.S. domestic issuers. Please reconcile these disclosures,
and advise whether you will be relying on Irish home country practice pursuant to the foreign private issuer exemptions.
RESPONSE: Disclosure have
been revised to clarify that the Company is a foreign private issuer which, while eligible for exemptions, has overtly stated that it
does not intend to rely on Irish home-country practices inconsistent with Nasdaq corporate governance standards.
Expenses of Issuance and Distribution,
page 1
11. Please explain the source of funds that will be used to
pay the estimated $871,900 of expenses in connection with the registration of your shares given that you have never generated revenue,
have de minimis cash on hand and will not receive any proceeds from the registration of your shares in a direct listing.
RESPONSE: Expenses table provided
showing $871,900 total, funded through non-interest-bearing advances from Malbrite Ltd. (owned by CEO Jack Kaye), repayable only upon
a capital raise. Note, we have expanded our disclosures to address related party nature of the funding commitment by the CEO.
Capitalization, page 1 5
12. We note the cash and cash equivalents balance presented within
Capitalization uses amounts as of December 31, 2023 . Please update for consistency with December 31, 2024 balances.
RESPONSE: Our capitalization
table has been revised to December 2024 balances, and not 2023.
3
Corporate History And Structure,
page 1 6
13. We note that Davion Healthcare Plc. (Cyprus) issued 12,258,458 ordinary shares in 2022, along with a further 7,741,542 ordinary shares in 2024 and an additional 5,000,000 ordinary shares
in 2024. Please disclose the price at which these ordinary shares were sold and briefly discuss the nature of each of these transactions,
including whether they were transactions exempt from registration under the Securities Act. Please also revise your risk factor disclosures,
as applicable, to note that recent sales prices for your ordinary shares may bear little or no relation to the trading price at or subsequent
to the opening of trading of the ordinary shares on Nasdaq.
RESPONSE: Our corporate history has been expanded:
Cyprus issuances in 2022–2024 were all at par (€0.01) in connection with capitalization and IP transfers and were exempt private
transactions not subject to the U.S. Securities Act. Additionally, we have referenced that the public share price my bear little or not
relation to recent private sales within the risk factor disclosures.
Management’s Discussion And
Analysis Of Consolidated Financial Condition And Results Of Operations
Overview of Business Operations,
page 23
14. We note your disclosure on page 24 that "it can only be
assumed that there is a large and open market of women who would wish to monitor their health in the privacy of their own home, particularly
given that the accuracy level [ of BreastCheck] is the same as a mammogram." Please substantiate your claim that BreastCheck has
the same accuracy level as a mammogram.
RESPONSE: Reference to BreastCheck accuracy
level versus mammogram removed; disclosure revised to avoid unsubstantiated equivalence claims.
Operating Results, page 27
15. Please provide a more detailed discussion of the material factors impacting the decrease in
expenses, and trends management expects in upcoming periods. Please discuss any material events and uncertainties that would cause
reported financial information not to be necessarily indicative of future operating results or of future financial condition. As a
pre-revenue company focusing on research and development, please also provide a breakdown of your research and development by
product, by function of costs (e. g. clinical, regulatory application), or by nature of costs (e.g. payroll, outsourcing
consultant). Refer to Item 5.A of Form 20-F.
RESPONSE: Our MD&A is now expanded to discuss
drivers of expense trends, R&D allocations (clinical, regulatory, outsourcing), and uncertainties impacting forward-looking results.
16. Please revise to explain the decline in your research and development
expenses during the comparative period.
RESPONSE: Decline in R&D expenses
explained as due to reduced external development activity after products reached near-final stage.
17. We note your disclosure on page 28 that "the Company secured
a significant agreement with NeuRX Health Inc of Rhode Island, USA, [ during the year ending December 31, 2024] for the manufacturing
and distribution of BreastCheck,"and that "the agreement will provide a steady revenue stream in the form of payments and annual
royalties based on product manufacturing and distribution volumes." We also note that an outline agreement was filed with NeuRX
Health as Exhibit 10.2 to the registration statement. Please revise to disclose the material terms of your agreement with NeuRX Health,
including payments and annual royalties due under the agreement. Please also advise if a final agreement has been entered into with NeuRX,
and if so, file such agreement as an exhibit to your registration statement. Refer to Item 10.C of Form 20-F.
RESPONSE: Material terms of NeuRX Health agreement
have now been added, including royalty-based payments tied to manufacturing/distribution volumes. Final executed agreement is now listed
as an exhibit.
4
Liquidity and Capital Resources,
page 28
18. We note your disclosure regarding the Company's reliance on
the personal financial support of the Chief Executive Officer, who has provided all funding to date. We also note on page 52 you state
that the financial support is provided through Malbrite Ltd. , a Company owned by Jack Kaye.
• Please
reconcile and expand your disclosures to provide information on material terms of any agreement between the Company and the provider
of financial support.
• We note
that Malbrite Ltd. is not listed as an affiliate shareholder on page 52, so it is not clear how the Company is settling any liabilities
from the financial support it receiv