United States securities and exchange commission logo
August 25, 2023
Xin 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
Annual Report on Form 20-F
Filed August 21,
2023
File No. 001-41291
Dear Xin Wang:
We have reviewed your August, 21, 2023 response to our comment
letter 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. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
August 15, 2023 letter.
Amendment No. 2 to Annual Report on Form 20-F, filed August 21, 2023
Item 3. Key Information, page 1
1. We note the changes you
made to your disclosure appearing in the Risk Factors section of
your amended annual
report for the fiscal year ended December 31, 2022 relating to legal
and operational risks
associated with operating in China and PRC regulations. The annual
report discloses
information as of your fiscal year ended December 31, 2022 and it is
unclear to us that
there were changes in the regulatory environment in the PRC for the
period covered by the
report warranting revised disclosure to mitigate the challenges you
face and related
disclosures. The Sample Letters to China-Based Companies sought
specific disclosure
relating to the risk that the PRC government may intervene in or
influence your
operations at any time, or may exert control over operations of your
Xin Wang
Meihua International Medical Technologies Co., Ltd.
August 25, 2023
Page 2
business, which could result in a material change in your operations
and/or the value of
the securities you have registered for sale. We remind you that, pursuant
to federal
securities rules, the term control (including the terms
controlling, controlled by, and
under common control with ) as defined in Securities Act Rule 405
means the
possession, direct or indirect, of the power to direct or cause the
direction of the
management and policies of a person, whether through the ownership of
voting securities,
by contract, or otherwise. The Sample Letters also sought specific
disclosures relating to
uncertainties regarding the enforcement of laws and that the rules and
regulations in China
can change quickly with little advance notice. Because your revised
disclosure has
removed references to the PRC government s power to exercise
significant oversight and
discretion over the conduct of your business, the level of government
involvement in the
Chinese economy, and the risk factors captioned PRC s economic,
political and social
conditions, as well as changes in any government policies, laws and
regulations, could
have a material adverse effect on our business and Uncertainties
with respect to the
PRC legal system could adversely affect us, we do not believe that
your revised
disclosure conveys these risks. We also note that your disclosure in the
Key Information
Related to Doing Business in China section at the outset of Item 3
continues to reference
the risk factors that were removed in your latest amendment. We further
note your
revision noting that you may not be able to effectively protect your
intellectual property
rights or to enforce your contractual rights in China or in other
jurisdictions. However,
you disclose that Meihua is not a Chinese operating company but a Cayman
Islands
holding company with all operations conducted by its subsidiaries located
in mainland
China. Please disclose the other jurisdictions where you hold
intellectual property. Please
restore your disclosures in these areas to the disclosures as they
existed in your annual
report as of July 3, 2023.
You may contact Al Pavot at 202-551-3738 or Terence O'Brien at
202-551-3355 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Conlon Danberg at 202-551-4466 or Margaret Schwartz at 202-551-7153
with any other
questions.
Sincerely,
FirstName LastNameXin Wang Division of Corporation
Finance
Office of Industrial
Applications and
Comapany NameMeihua International Medical Technologies Co., Ltd.
Services
August 25, 2023 Page 2
cc: Megan J. Penick, Esq.
FirstName LastName