View:
United States securities and exchange commission logo
June 14, 2023
Danny Yeung
Chief Executive Officer
Prenetics Global Limited
Unit 701-706, K11 Atelier King s Road 728 King s Road, Quarry Bay
Hong Kong
Re: Prenetics Global
Limited
Post-Effective
Amendment No. 3 for Registration Statement on Form F-1
Filed May 31, 2023
File No. 333-265284
Dear Danny Yeung:
We have reviewed your post-effective amendment 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 amending your registration
statement and providing the
requested information. 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 any amendment to your registration statement and
the information you
provide in response to these comments, we may have additional comments.
Post-Effective Amendment No. 3 for Registration Statement on Form F-1
filed on May 31, 2023
Cover Page
1. We note your response
to our prior comment number 3 and reissue in part. We note your
disclosure on the cover
page stating Prenetics Global Limited is a Cayman Islands
holding company with
operations primarily conducted by its subsidiaries and further
stating [w]e have
subsidiaries conducting operations in Hong Kong." We note in your
response you point to
the diagram in the Prospectus Summary of the organizational
structure. Please state
specifically on the cover page which entities conduct the company's
operations and,
specifically, which entities conduct operations in Hong Kong, including
the entities from the
recent acquisition of ACT Genomics.
Danny Yeung
FirstName LastNameDanny
Prenetics Global Limited Yeung
Comapany
June NamePrenetics Global Limited
14, 2023
June 14,
Page 2 2023 Page 2
FirstName LastName
Prospectus Summary, page 1
2. We note your response to our prior comment number 2 and reissue in
part. Please revise
the Prospectus Summary to address the risks highlighted on the cover
page in response to
our prior comment number 2.
3. Please revise to provide more information about your historical
minority interest in a
genomics business in mainland China, which is mentioned on page 3.
General
4. We note your response to our prior comment number 12. We also note the
added cover
page and Risk Factor disclosure, including your disclosure that you
"consider that the
current laws and regulations of the PRC applicable to mainland China
have no material
impact on [y]our business" however, you "must contend with
uncertainties stemming from
the PRC's intricate and evolving legal and regulatory landscape."
Despite your view that
there has not been any impact thus far, the risk should be
definitively stated. Please revise
your disclosure on the cover page to state that the legal and
operational risks associated
with operating in China also apply to operations in Hong Kong and
Macau.
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.
You may contact Nicholas O'Leary at 202-551-4451 or Margaret Schwartz
at 202-551-
7153 if you have questions.
Sincerely,
Division of
Corporation Finance
Office of
Industrial Applications and
Services
cc: Jonathan Stone, Esq.