United States securities and exchange commission logo
July 29, 2021
Yulin Wang
Chief Executive Officer
Meihua International Medical Technologies Co., Ltd.
88 Tongda Road, Touqiao Town
Guangling District, Yangzhou, 225000
People s Republic of China
Re: Meihua
International Medical Technologies Co., Ltd.
Amendment No. 2 to
Draft Registration
Statement on Form F-1
July 16, 2021
CIK No. 0001835615
Dear Mr. Wang:
We have reviewed your amended draft registration statement and
have the following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.
Please respond to this letter by providing the requested
information and either submitting
an amended draft registration statement or publicly filing your
registration statement on
EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
believe an amendment is appropriate, please tell us why in your
response.
After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we
may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1
Prospectus Summary
Implications of Being an Emerging Growth Company, page 10
1. Please expand your
disclosure to include your conclusion to opt-in to the extended
transition period to
adopt new or revised accounting standards. Also provide disclosure
that this election may
result in your financial statements not be comparable to other
entities that adopt new
or revised accounting standards using the public company adoption
requirements. Address
this comment in your risk factors and in management's discussion
and analysis sections.
Yulin Wang
Meihua International Medical Technologies Co., Ltd.
July 29, 2021
Page 2
Risks Related to Doing Business in China, page 26
2. Please include risk factor disclosure, where appropriate, related to
the potential impact of
the Holding Foreign Companies Accountable Act on your ability to do
business in China.
Our Customers, page 71
3. We note your response to our prior comment 12. Please clarify whether
your direct end
user customers and export distributor customers are based in China.
Please also restore
your disclosure with respect to your top three customers for the years
ended December 31,
2019 and 2020, and also identify which type of customer for each of
the three customers.
Consolidated Statements of Cash Flows, page F-6
4. Please tell us why the $344,739 is recognized in equity as a
subscription for ordinary
shares and included as a financing cash inflow during fiscal year 2019
and what was
provided in exchange. In this regard, we note that when the
subscription was released in
fiscal year 2020, no ordinary shares were recognized as outstanding or
a corresponding
financing cash outflow was recognized during fiscal year 2020.
1. Organization and Principal Activities
Reorganization and Share Issuance, page F-8
5. We note your responses to comments 17 and 18 along with the expanded
disclosure
provided to Note 1. Please tell us how you concluded that the
transaction with Yongjun
Liu and Yin Liu to acquire 100% ownership of Kangfu represents a
corporate
reorganization to roll controlled entities into one legal corporation.
In this regard, we note
that the three BVI companies, or founders of Meihua, held 2,640,000
ordinary shares of
Meihua, while Yongjun Liu and Yin Liu held 2,000 ordinary shares of
Meihua.
Revenue Disaggregation, page F-13
6. We note your response to comment 21 along with your expanded disclosure.
Please tell
us your consideration of providing disaggregated revenue information by
domestic versus
FirstName LastNameYulin Wang
overseas revenues and also direct sales, domestic distributors, and
exporting distributors
Comapany NameMeihua
revenues. International
In this regard, Medical
we reference Technologies
your disclosuresCo., Ltd. 4 of
the Form S-1. Refer
on page
July 29,to2021
ASCPage
606-10-55-89
2 through 55-91 for additional guidance.
FirstName LastName
Yulin Wang
FirstName LastNameYulin Wang
Meihua International Medical Technologies Co., Ltd.
Comapany
July NameMeihua International Medical Technologies Co., Ltd.
29, 2021
July 29,
Page 3 2021 Page 3
FirstName LastName
14. Segment Information, page F-22
7. We note that you have now concluded that you have 2 reportable
segments in accordance
with the guidance in ASC 280-10-50. Please provide the disclosures
required by ASC
280-10-50-22 through 50-31. As previously requested, also provide the
enterprise-wide
information required by ASC 280-10-50-38 through 50-41. In this
regard, we note your
disclosures throughout the Form S-1 that you offer three different
product categories,
Class I, Class II, and Class II, each representing differing degrees
of risk in terms of safety
and effectiveness.
You may contact Tracey Houser at 202-551-3736 or Brian Cascio at
202-551-3676 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jane Park at 202-551-7439 or Celeste Murphy at 202-551-3257 with any
other questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences
cc: Joe Laxague, Esq.