United States securities and exchange commission logo
December 19, 2022
Guo-Liang Yu
Chief Executive Officer
Apollomics Inc.
989 E. Hillsdale Blvd., Suite 220
Foster City, CA 94404
Re: Apollomics Inc.
Amendment No. 1 to
Registration Statement on Form F-4
Filed December 15,
2022
File No. 333-268525
Dear Guo-Liang Yu:
We have reviewed your amended 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 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.
Unless we note
otherwise, our references to prior comments are to comments in our
December 5, 2022 letter.
Amendment No. 1 to Registration Statement on Form F-4
Information about Apollomics
Drug Candidate Development Status, page 215
1. We note your revised
disclosure in response to prior comment 6 and reissue in
part. Please remove the
third party trials from your pipeline table as disclosure indicates
you do not have any
direct financial interest in the development of these product
candidates by third
parties. We will not object to a narrative discussion of your rights to
access clinical trial
data and potential to benefit from feedback from regulators.
Guo-Liang Yu
FirstName
ApollomicsLastNameGuo-Liang Yu
Inc.
Comapany19,
December NameApollomics
2022 Inc.
December
Page 2 19, 2022 Page 2
FirstName LastName
Employment Agreements, page 337
2. Please file the employment agreements entered into with your executive
officers as
exhibits to your registration statement. Refer to Item
601(b)(10)(ii)(A) of Regulation S-K
for guidance.
You may contact Christine Torney at 202-551-3652 or Kevin Vaughn at
202-551-3494 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Tyler Howes at 202-551-3370 or Christine Westbrook at 202-551-5019 with
any other
questions.
Sincerely,
Division of
Corporation Finance
Office of Life
Sciences
cc: Daniel Nussen, Esq.