United States securities and exchange commission logo
August 14, 2023
Wei-Wu He
Chief Executive Officer
CASI Pharmaceuticals, Inc.
1701-1702, China Central Office Tower 1
No. 81 Jianguo Road Chaoyang District
Beijing, 100025
People s Republic of China
Re: CASI
Pharmaceuticals, Inc.
Form 20-F for the
Fiscal Year December 31, 2022
File No. 001-41666
Dear Wei-Wu He:
We have limited our review of your filing to the submission
and/or disclosures as
required by Item 16I of Form 20-F 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 these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 98
1. We note your statement
that you reviewed your register of members and public filings
made by your
shareholders in connection with your required submission under paragraph
(a). Please
supplementally describe any additional materials that were reviewed and tell
us whether you relied
upon any legal opinions or third party certifications such as
affidavits as the basis
for your submission. In your response, please provide a similarly
detailed discussion of
the materials reviewed and legal opinions or third party
certifications relied
upon in connection with the required disclosures under paragraphs
(b)(2) and (3).
2. In order to clarify the
scope of your review, please supplementally describe the steps you
have taken to confirm
that none of the members of your board or the boards of your
consolidated foreign
operating entities are officials of the Chinese Communist Party. For
Wei-Wu He
CASI Pharmaceuticals, Inc.
August 14, 2023
Page 2
instance, please tell us how the board members current or prior
memberships on, or
affiliations with, committees of the Chinese Communist Party factored
into your
determination. In addition, please tell us whether you have relied upon
third party
certifications such as affidavits as the basis for your disclosure.
3. We note that your disclosures pursuant to Items 16I(b)(3) and (b)(5) are
provided for
CASI Pharmaceuticals, Inc. Please note that Item 16I(b) requires
that you provide
disclosures for yourself and your consolidated foreign operating
entities. With respect to
(b)(3) and (b)(5) please provide the required information for you and all
of your
consolidated foreign operating entities in your supplemental response.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Austin Pattan at (202) 551-6756 or Christopher Dunham at
(202) 551-
3783 with any questions.
Sincerely,
FirstName LastNameWei-Wu He
Division of
Corporation Finance
Comapany NameCASI Pharmaceuticals, Inc.
Disclosure Review
Program
August 14, 2023 Page 2
cc: Peter Huang
FirstName LastName