Meihua International Medical Technologies (MHUA)
Filed: 21 Aug 23, 12:00am
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People’s Republic of China
August 21, 2023
Division of Corporation Finance
Office of Industrial Applications and Services
U.S. Securities and Exchange Commission
Washington, D.C. 20549
| Attn: | Mr. Conlon Danberg |
| Ms. Margaret Schwartz |
| Re: | Meihua International Medical Technologies Co., Ltd. | |
| Amendment No. 1 to Annual Report on Form 20-F | ||
| Filed July 3, 2023 | ||
| File No. 001-41291 |
Ladies and Gentlemen:
We are hereby transmitting the response of Meihua International Medical Technologies Co., Ltd. a Cayman company (the “Company,” “we,” or “our”), to the comment letter we received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on August 15, 2023, regarding the Company’s Amendment No.1 to our Annual Report on Form 20-F filed with the Commission on July 3, 2023. An Amendment No. 2 to the Form 20-F (the “Amended No.2 to Form 20-F”) is being submitted to the Commission concurrently with this letter.
For your convenience, we have repeated below the comments of the Staff in bold and have followed the Staff’s comments with the Company’s response.
Amendment No. 1 to Annual Report on Form 20-F, filed July 3, 2023
Item 3. Key Information, page 1
1. We note your response to previous comment 1 and re-issue the comment in part. We acknowledge that the Company does not have operations in Macau at this time. However, it is possible that the Company will commence operations in Macau in the future. Therefore, please expand on your new disclosure at the outset of Item 3. Key Information—D. Risk Factors to state that such legal and operational risks would apply to any operations in Macau. Alternatively, please remove the carve out for the special administrative region of Macau from the defined term “China” or the “PRC” in the Use of Certain Defined Terms section.
Response: In response to the Staff’s comment, we expanded our disclosure at the outset of Item 3. Key Information—D. Risk Factors to state that such legal and operational risks would apply to any operations in Macau (see page 7 of Amendment No. 2 to Form 20-F). In addition, we also revised the definition of the term “China” or the “PRC” in the Use of Certain Defined Terms section to include the special administrative regions of Hong Kong and Macau (see page ii of Amendment No. 2 to Form 20-F).
We thank the Staff in advance for its review of the foregoing in relation to the Company’s filing of its Amended No. 2 to Form 20-F. Should you have any questions or concerns, please kindly contact our counsel, Megan J. Penick, Esq. of Michelman & Robinson, LLP, by telephone at (646) 320-4104 or mpenick@mrllp.com.
| Sincerely, | |
| /s/ Xin Wang | |
| Xin Wang | |
| Chief Executive Officer | |
| Meihua International Medical Technologies Co., Ltd. |