View:
United States securities and exchange commission logo
October 28, 2021
Danny Yeung
Director
Prenetics Global Limited
Unit 701-706, K11 Atelier King s Road
728 King s Road, Quarry Bay
Hong Kong
Re: Prenetics Global
Limited
Draft Registration
Statement on Form F-4
Submitted September
30, 2021
CIK 0001876431
Dear Mr. Yeung:
We have reviewed your 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.
Draft Registration Statement on Form F-4
Cover Page
1. Please disclose
prominently on the cover page that you are not a Hong Kong operating
company but a Cayman
Islands holding company. Clarify whether your operations are
conducted by
subsidiaries and/or through contractual arrangements with variable interest
entities (VIEs) based
in China, and that this structure involves unique risks to investors. If
applicable, explain
whether the VIE structure is used to replicate foreign investment in
Chinese-based companies
where Chinese law prohibits direct foreign investment in the
operating companies,
and disclose that investors may never directly hold equity interests
in the Chinese
operating company. Your disclosure should acknowledge that Chinese
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 2 28, 2021 Page 2
FirstName LastName
regulatory authorities could disallow this structure, which would
likely result in a material
change in your operations and/or value of your ordinary shares,
including that it could
cause the value of such securities to significantly decline or become
worthless. Provide a
cross-reference to your detailed discussion of risks facing the
company and the offering as
a result of this structure.
2. Please revise the cover page to:
disclose the expected ownership percentages in the combined
company of Artisan's
public shareholders, the Sponsor, the Forward Purchase Investors,
the PIPE Investors,
Prenetics existing shareholders other than Danny Yeung and Danny
Yeung if the
business combination is approved and consummated; and
quantify the business combination consideration.
3. We note your disclosure indicating that Danny Yeung will beneficially
own
approximately 60.7% of the total voting power of all issued and
outstanding PubCo
Ordinary Shares following the consummation of the Business Combination
(subject to
various assumptions). Please advise whether you will be a controlled
company under
Nasdaq rules. If so, please (i) include appropriate disclosure on the
prospectus cover page,
in the Prospectus Summary and Management of PubCo sections and provide
risk factor
disclosure of this status and (ii) disclose the corporate governance
exemptions available to
a controlled company and whether you intend to rely on these
exemptions.
4. Provide prominent disclosure about the legal and operational risks
associated with being
based in or having the majority of the company s operations in Hong
Kong and China.
Your disclosure should make clear whether these risks could result in
a material change in
your operations and/or the value of your ordinary shares or could
significantly limit or
completely hinder your ability to offer or continue to offer
securities to investors and
cause the value of such securities to significantly decline or be
worthless. Your disclosure
should address how recent statements and regulatory actions by China
s government, such
as those related to the use of variable interest entities and data
security or anti-monopoly
concerns, has or may impact the company s ability to conduct its
business, accept foreign
investments, or list on an U.S. or other foreign exchange. Your
prospectus summary
should address, but not necessarily be limited to, the risks
highlighted on the prospectus
cover page.
5. Clearly disclose how you will refer to the holding company,
subsidiaries, and VIEs, if
applicable, when providing the disclosure throughout the document so
that it is clear to
investors which entity the disclosure is referencing and which
subsidiaries or entities are
conducting the business operations. Refrain from using terms such as
we or our when
describing activities or functions of a VIE, if applicable. Disclose
clearly the entity
(including the domicile) in which investors are purchasing their
interest.
Industry and Market Data, page 3
6. We note your statements that (i) the accuracy and completeness of
information used in
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 3 28, 2021 Page 3
FirstName LastName
industry reports, publications, research, studies and forecasts is not
guaranteed and (ii) you
have not independently verified data from industry sources. We further
note your
statement on page 175 that neither you nor any other party has
independently verified the
information presented in this section and that neither you nor any
other party makes any
representation as to the accuracy or completeness of such information.
These statements
may imply an inappropriate disclaimer of responsibility with respect
to such information
that appears in the proxy statement/prospectus. Please either delete
these statements or
specifically state that you or a named expert, as applicable, are
liable for such information.
Questions and Answers About the Proposals
What shall be the relative equity stakes of Artisan shareholders, Prenetics
shareholders and the
PIPE Investors..., page 8
7. Please revise the response to this question to also include the voting
power of the parties
that appear in the share ownership table.
8. Please revise the response to this question to disclose all possible
sources and extent of
dilution that shareholders who elect not to redeem their shares may
experience in
connection with the business combination. Provide disclosure of the
impact of each
significant source of dilution, including the amount of equity held by
founders,
convertible securities, including warrants retained by redeeming
shareholders, at each of
the redemption levels detailed in your sensitivity analysis, including
any needed
assumptions.
What interests do Artisan's Directors and Officer have in the Business
Combination?, page 13
9. Please revise the response to this question and elsewhere in the
prospectus, as appropriate,
to clarify if the Sponsor and its affiliates can earn a positive rate
of return on their
investment, even if other Artisan shareholders experience a negative
rate of return in the
post-business combination company.
10. Please revise the response to this question and elsewhere in the
prospectus, as
appropriate, to disclose the sponsor and its affiliates total
potential ownership interest in
the combined company, assuming exercise and conversion of all
securities.
Summary of the Proxy Statement/Prospectus, page 23
11. Clearly describe the corporate structure and whether it includes VIEs
based in China and
what that entails. Prominently disclose a diagram of the corporate
structure in the
summary, including what the equity ownership interests are of each
entity. To the extent
you do use VIEs, describe all contracts and arrangements through which
you purport to
obtain economic rights and exercise control that results in
consolidation of the VIE s
operations and financial results into your financial statements.
Identify clearly the entity in
which investors are purchasing their interest and the entity(ies) in
which the company s
operations are conducted. Describe the relevant contractual agreements
between the
entities and how this type of corporate structure may affect investors
and the value of their
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 4 28, 2021 Page 4
FirstName LastName
investment, including how and why the contractual arrangements may be
less effective
than direct ownership and that the company may incur substantial costs
to enforce the
terms of the arrangements. Disclose the uncertainties regarding the
status of the rights of
the Cayman Islands holding company with respect to any applicable
contractual
arrangements with the VIE, its founders and owners, and the challenges
the company may
face enforcing these contractual agreements due to uncertainties under
Chinese law and
jurisdictional limits.
12. Prominently disclose each permission that you, your subsidiaries or
your VIEs, if
applicable, are required to obtain from Chinese authorities to operate
and issue these
securities to foreign investors. State whether you, your subsidiaries,
or VIEs, if
applicable, are covered by permissions requirements from the CSRC, CAC
or any other
entity that is required to approve of the VIE s or the subsidiary
s operations, and state
affirmatively whether you have received all requisite permissions and
whether any
permissions have been denied.
13. Please disclose the composition of the board of directors of PubCo
after consummation of
the Business Combination in relation to members associated with each
of the pre-
acquisition entities.
14. In your summary of risk factors, disclose the risks that your
corporate structure and being
based in or having the majority of the company s operations in Hong
Kong poses to
investors. In particular, describe the significant regulatory,
liquidity, and enforcement
risks with cross-references to the more detailed discussion of these
risks in the
prospectus. For example, specifically discuss risks arising from the
legal system in China
and Hong Kong, including risks and uncertainties regarding the
enforcement of laws and
that rules and regulations in China and Hong Kong can change quickly
with little advance
notice; and the risk that the Chinese government may intervene or
influence your
operations at any time, or may exert more control over offerings
conducted overseas
and/or foreign investment in China-based or Hong Kong-based issuers,
which could result
in a material change in your operations and/or the value of your
ordinary
shares. Acknowledge any risks that any actions by the Chinese
government to exert more
oversight and control over offerings that are conducted overseas
and/or foreign investment
in China-based or Hong Kong-based issuers could significantly limit or
completely hinder
your ability to offer or continue to offer securities to investors and
cause the value of such
securities to significantly decline or be worthless.
15. Prominently disclose that trading in your securities may be prohibited
under the Holding
Foreign Companies Accountable Act and your shares could be prohibited
from trading if
the PCAOB determines that it cannot inspect or fully investigate your
auditor, and that as
a result an exchange may determine to delist your securities. If the
PCAOB has been or is
currently unable to inspect your auditor, revise your disclosure to so
state. Please ensure
that your disclosure indicates that the U.S. Senate passed the
Accelerating Holding
Foreign Companies Accountable Act which, if enacted, would require
foreign companies
to comply with PCAOB audits within two consecutive years instead of
three, thus
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 5 28, 2021 Page 5
FirstName LastName
reducing the time period for triggering the prohibition on trading.
The Artisan Board's Reasons for the Approval of the Business Combination, page
27
16. Please revise your disclosure here and on page 143 to disclose whether
Artisan's Board
considered any risks related to Prenetics's business in evaluating
whether to approve the
Business Combination. To the extent Artisan's Board considered any
such risks, please
describe them. If Artisan's Board did not consider any such risks,
please so state and
disclose why the Artisan Board did not consider risks related to
Prenetics's business in its
decision to approve the Business Combination.
17. Please revise the Financial Performance bullet here and on page 142 to
reflect your
disclosure elsewhere in the prospectus that a significant majority of
the Prenetics's
revenue growth in 2020 and in 2021 to date was driven by COVID-19
diagnostic testing.
Please also revise this bullet to reflect your disclosure on page 146
indicating that
Prenetics's management projected net losses in each of Prenetics's
next five fiscal years.
18. Please revise the Continued Support by Existing Shareholders bullet to
briefly disclose
how long the post-closing lock-up arrangements for major shareholders
of Prenetics will
last.
19. Please revise this section to disclose the material risks to
unaffiliated investors presented
by taking the company public through a merger rather than an
underwritten offering.
These risks could include the absence of due diligence conducted by an
underwriter that
would be subject to liability for any material misstatements or
omissions in a registration
statement.
Risk Factors, page 48
20. Please revise both the Risk Factor Summary and the Risk Factors
section to prominently
display and discuss the risks of doing business in Hong Kong.
21. Given the Chinese government s significant oversight and discretion
over the conduct of
your business, please revise to separately highlight the risk that the
Chinese government
may intervene or influence your operations at any time, which could
result in a material
change in your operations and/or the value of your ordinary shares.
Also, given recent
statements by the Chinese government indicating an intent to exert
more oversight and
control over offerings that are conducted overseas and/or foreign
investment in China-
based issuers, acknowledge the risk that any such action could
significantly limit or
completely hinder your ability to offer or continue to offer
securities to investors and
cause the value of such securities to significantly decline or be
worthless.
22. In light of recent events indicating greater oversight by the
Cyberspace Administration of
China over data security, particularly for companies seeking to list
on a foreign exchange,
please revise your disclosure to explain how this oversight impacts
your business and your
offering and to what extent you believe that you are compliant with
the regulations or
policies that have been issued by the CAC to date.
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 6 28, 2021 Page 6
FirstName LastName
Prenetics's business, financial condition and results of operations and/or the
value of PubCo's
shares..., page 74
23. We note your statement on page 74 that Prenetics "does not have
business operations and
does not offer its services and products in Mainland China." However,
we also note the
list of subsidiaries on page F-31 that you state "principally affected
the results, assets or
liabilities of the Group", four of which are incorporated in the PRC,
and the joint venture
with Berry Genomics operating as a genetic testing company in mainland
China of which
Prenetics owns 45%. Please revise your disclosure throughout the
document to clearly
describe all operations, whether direct or indirect, that Prenetics
conducts in Mainland
China.
Organizational Structure, page 129
24. We note that "indirect subsidiaries" of Prenetics are shown in the
post-Business
Combination org chart on page 131. Please clarify the nature and
extent of Prenetic's
ownership of these entities on a post-combination basis.
Background of the Business Combination, page 131
25. We note your statement that the disclosure in this section is not, and
does purport to be, a
complete catalogue of every interaction between the applicable
parties. Please revise your
disclosure to clarify that you are required to present all material
information regarding the
negotiation of the Business Combination to investors. Please also
ensure that this section
contains all such information.
26. Your disclosure on page 133 indicates that Artisan and Prenetics held
a due diligence call
on June 2, 2021 regarding Prenetics's historical financials and
management projections for
its respective business segments. Please tell us if this information
was presented to
Artisan's Board. To the extent that this information was presented to
Artisan's Board and
that Artisan's Board considered it in its decision to approve the
Business Combination,
please include it in the prospectus.
27. Please revise your disclosure in this section to disclose how
Artisan's management and the
Artisan Board determined a pre-money equity valuation of $1.15 billion
for Prenetics. To
the extent that this valuation changed between the signing of the LOI
on June 21, 2021
and the execution of the definitive agreement, please describe any
such changes. In that
regard, we note that the press releases announcing the transaction
refer to an enterprise
value of $1.25 billion for Prenetics.
Please also revise to present the "analysis of Prenetics's valuation
in a potential business
combination with Artisan" described on page 134 as being reviewed by
Artisan's board on
June 17, 2021 and ensure that all material information from the
presentation to PIPE
investors referenced throughout this section is included in the proxy
statement/prospectus.
28. Please revise the disclosure concerning the Artisan Board's reasons
for approval of the
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 7 28, 2021 Page 7
FirstName LastName
Business Combination in the subsections beginning on page 27 and page
140 to discuss
whether the Artisan Board considered forming an independent committee
to evaluate the
Business Combination given your disclosure that an affiliate of the
Sponsor 1) entered
into a collaboration agreement with Prenetics while transaction
negotiations between
Prenetics and Artisan were ongoing, and 2) entered into a convertible
note subscription
agreement with Prenetics Limited in February 2021, the same month that
Artisan was
incorporated.
Certain Prospective Operational and Financial Information, page 145
29. In regards to the Prenetics Management Projections, please expand your
disclosures to
address the following:
Further explain the nature of the material assumptions underlying
the line items
presented. Please ensure the level of detail provided is
sufficient enough for an
investor to understand the reasonableness of the assumptions
underlying
the projections as well as the inherent limitations on the
reliability of projections in
order to make informed investment decisions. In regards to the
revenue and gross
margin projected amounts, please specifically address the
significant revenue and
gross margin growth rates as well as identify the material
product revenues streams
underlying these projections;
In regards to the length of the projections, please disclose the
basis for projections
beyond year three including if the forecasts reflect more than
simple assumptions
about growth rates;
Explain how management and the Board considered and relied upon
these
projections; and
In the reconciliation from Adjusted EBITDA to Net Profit, please
further clarify the
other non-operating expenses being excluded from the
determination of Adjusted
EBITDA.
Certain Engagements in connection with the Business Combination and Related
Transactions,
page 149
30. We note that UBS and Credit Suisse performed additional services after
the IPO and part
of the IPO underwriting fee was deferred and conditioned on completion
of a business
combination. Please quantify the aggregate fees payable to UBS and
Credit Suisse that are
contingent on completion of the business combination.
Prenetics's Business
Overview, page 185
31. We note your statement on pages 185-86 that the nucleic acid
amplification test achieved
95.6% sensitivity and 100% specificity. Please revise your disclosure
to clarify whether
this study was evaluating the Circle HealthPod. Please also revise
your disclosure in this
section, where appropriate, to describe the study's material
parameters including the
number of participants enrolled, primary endpoints and duration.
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 8 28, 2021 Page 8
FirstName LastName
32. Please revise this section, where appropriate, to describe the
material terms of Prenetics's
acquisition of Oxsed, including any earnouts.
Our History, page 187
33. We note that you identify certain entities as investors in Prenetics.
However, certain of
these entities do not appear to be among PubCo's principal
stockholders as disclosed on
page 283. If material, please expand your disclosure to describe the
nature of each such
entity's investment in Prenetics and explain to us why including this
information is
appropriate. Please also explain in the response your plans to update
investors about any
changes these entities make with respect to their investments in your
company.
Alternatively, please remove these entities from your disclosure.
Circle HealthPod, page 194
34. We note your statements on page 196 indicating that New World
Development has
purchased Circle HealthPod devices and capsules and on page 203 that
Prenetics's
collaboration with New World Development provides a strong testament
of its
commercial strategy. Please revise each of these statements to reflect
your disclosure
elsewhere in the prospectus that Adrian Cheng, the founder of Artisan
and the Sponsor, is
also the CEO and executive vice chairman of New World Development and
that
the collaboration was entered into while Artisan and Prenetics were
negotiating the terms
of the Business Combination.
Our Pipeline Products and Services, page 196
35. We note your statement on page 196 indicating that ColoClear has an
estimated 95.5%
sensitivity. Please revise your disclosure in the Prenetics's Business
section, where
appropriate, to describe the material protocols of the study(ies)
where ColoClear was
evaluated (including number of patients treated and primary endpoints)
and how it was
determined that ColoClear has estimated 95.5% sensitivity. Please also
revise to disclose
whether Prenetics will need to obtain regulatory approvals before it
can commercialize
ColoClear.
Intellectual Property, page 207
36. Please disclose the jurisdictions of Prenetics's pending patent
applications and the
expiration dates, if the patents are issued.
37. Please revise the description of each of the license agreements in
this section to disclose:
each parties' rights and obligations under the agreement;
quantify all payment made to date;
disclose separately the aggregate amount of all potential
development, regulatory and
commercial milestone payments;
quantify the royalty rate, or a range no greater than 10
percentage points per tier;
disclose when royalty provisions expire, if the expiration is
based on a number of
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 9 28, 2021 Page 9
FirstName LastName
years following commercialization, disclose the number of years;
disclose the expiration date; and
describe any termination provisions.
Description of the Business Combination, page 237
38. Please also disclose the terms of the conversion of Artisan Class A
and Artisan Class B
shares into Class A and Class B of PubCo shares. It appears that
holders of Artisan Class
B shares are receiving Class A shares of PubCo.
Note 3. Prenetics Corporate Restructuring, page 248
39. As part of the restructuring in June 2021, the convertible securities
of Prenetics Limited
were converted into Series D Preferred Shares of Prenetics Group
Limited. Please
disclose the key terms of these preferred shares and correspondingly
how you determined
equity classification was appropriate under IAS 32.
40. Please also disclose the material terms of the Series E Funding,
including the key terms of
these Series E preferred shares and correspondingly how you determined
equity
classification was appropriate under IAS 32.
Unaudited Pro Forma Condensed Combined Financial Information
Note 4. Adjustments to Unaudited Pro Forma Condensed Combined Financial
Information, page
248
41. As part of the business combination transaction, restricted share
units previously held will
be converted into PubCo restricted share units. Please disclose how
you will be
accounting for this exchange under IFRS 2 and correspondingly how you
determined that
the conversion would lead to the elimination of share-based
compensation expense as
addressed in Adjustment DD.
42. In regards to Adjustment O and EE, please expand your disclosures to
further address how
this amount was determined, including the significant estimates and
assumptions used to
arrive at this pro forma expense amount as well as the calculation
used.
Description of PubCo Securities
Ordinary Shares, page 270
43. Please revise your disclosure to provide the definition of a
"Permitted Transferee" of a
holder of Class B Ordinary Shares.
Report of Independent Registered Public Accounting Firm, page F-2
44. We note that the Independent Auditor s Report does not include an
opinion on the
consolidated statements of financial position of Prenetics Limited and
subsidiaries as of
January 1, 2019. Please provide a revised report or advise.
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 10 28, 2021 Page 10
FirstName LastName
(a) Statement of Compliance, page F-7
45. You state that although IFRSs have been fully converged with IFRSs in
all material
respects since January 1, 2005, these financial statements are the
first issued financial
statements in which the Group makes an explicit and unreserved
statement of compliance
with IFRSs. It is not clear if there is a typographical error when
stating that "although
IFRSs have been fully converged with IFRSs." Please revise as
necessary.
Notes to the Consolidated Financial Statements, page F-6
46. We note the various patent license as well as collaboration agreements
disclosed
beginning on page 207. Please disclose the aggregate payments made
under these
agreements as well as the material terms of these agreements,
including the following:
each parties rights and obligations;
financial terms, including potential milestone payments and
royalty payments;
duration of the agreement; and
termination provisions.
(d) Subsidiaries and Non-controlling Interests, page F-8
47. We note that the Group controls an entity when it is exposed, or has
rights, to variable
returns from its involvement with the entity and has the ability to
affect those returns
through its power over the entity. When assessing whether the Group
has power, only
substantive rights (held by the Group and other parties) are
considered. Please tell us
whether you have consolidated any entities for which you have
determined that you have
power over the entities though do not have the majority of the voting
rights pursuant to
IFRS 10.
Note 2. Significant Accounting Policies
(q) Revenue and Other Income, page F-14
48. Pursuant to IFRS 15.119(b), please clarify in your disclosures whether
any of
your consideration amounts are variable and whether the estimate of
variable
consideration is typically constrained.
Note 3. Segment Information, page F-21
49. Please tell us what consideration you gave to providing the product
and services
disclosures under IFRS 8.32. Specifically we note the different
products and services
disclosed including on page F-7 and we also note the update services
discussed on page
F-15.
Note 5. Other Income and Other Net Losses, page F-23
50. We note you include other income and other net losses and share of
loss of a joint venture
in your determination of loss from operations. Please help us better
understand how you
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
October 28,NamePrenetics
2021 Global Limited
October
Page 11 28, 2021 Page 11
FirstName LastName
determined it was appropriate to include net exchange losses,
impairment loss on interest
in joint venture, sundry income, bank interest income, and share of
loss of a joint venture
in your determination of loss from operations. Please refer to IAS
1.BC56 and Rule 5-
03(b) of Regulation S-X.
Note 13. Interest in Joint Venture, page F-31
51. In regards to your joint venture, please address the following:
Pursuant to IFRS 12.22, please disclose the nature and extent of
any significant
restrictions on the ability of the joint venture to transfer
funds to you as well as the
unrecognised share of losses both for the reporting period and
cumulatively as you
have stopped recognising your share of losses of the joint
venture;
We note that there are amounts due from the joint venture due to
expenses paid on
behalf of the joint venture. Please expand your disclosures
pursuant to IFRS 12.23 to
discuss risks associated with your interests including any
commitments you have in
place related to the joint venture;
Please help us understand what led to reversal of provision for
impairment loss on
interest in joint venture recorded during the period ended March
31, 2021;
We note your statement on page 74 that you do not have business
operations and
or offer your services and products in Mainland China. Please
help us understand
what consideration you gave to this joint venture in making this
statement.
Note 30. Acquisition, page F-48
52. We note that the intellectual property rights intangible asset
recorded from the Oxsed
Limited acquisition represent approximately 22% of your total assets
at December 31,
2020. In this regard, please help us better understand how you
determined the appropriate
useful life of this intangible asset to be 20 years pursuant to IAS
38.88 through 96.
Exhibits
53. Please file an opinion as to the material tax consequences of the
domestication and the
merger. Refer to Item 601(b)(8) of Regulation S-K and Section III.A.2
of Staff Legal
Bulletin No. 19.
Danny Yeung
Prenetics Global Limited
October 28, 2021
Page 12
You may contact Nudrat Salik at 202-551-3692 or Mary Mast at
202-551-3613 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Alan Campbell at 202-551-4224 or Laura Crotty at 202-551-7614 with any
other
questions.
Sincerely,
FirstName LastNameDanny Yeung
Division of
Corporation Finance
Comapany NamePrenetics Global Limited
Office of Life
Sciences
October 28, 2021 Page 12
cc: Steve Lin
FirstName LastName