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United States securities and exchange commission logo
April 12, 2024
Sanjeev Redkar
President
Apollomics Inc.
989 E. Hillsdale Blvd., Suite 220
Foster City, CA 94404
Re: Apollomics Inc.
Registration
Statement on Form F-3
Filed April 1, 2024
File No. 333-278431
Dear Sanjeev Redkar:
We have conducted a limited review of your registration statement
and have the
following comment.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Registration Statement on Form F-3
General
1. We note your cover page
states you conduct operations through your wholly owned
subsidiary in mainland
China. To the extent you do not conduct the majority of your
operations in China,
please provide us your analysis supporting this. To the extent you
conduct the majority of
your operations in China, please revise your filing, as applicable,
to provide more
specific and prominent disclosures about the legal and operational risks
associated with
China-based companies. For additional guidance, please see the Division
of Corporation
Finance's Sample Letter to China-Based Companies issued by the Staff in
December 2021 and the
Sample Letter to Companies Regarding China-Specific
Disclosures issued by
the Staff in July 2023. In this regard, we note your Amendment
Number 4 to the
Registration Statement on Form F-4 filed February 21, 2023 appears to
address many of the
issues identified in the December 2021 letter.
Sanjeev Redkar
Apollomics Inc.
April 12, 2024
Page 2
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Daniel Crawford at 202-551-7767 or Tim Buchmiller at
202-551-3635
with any other questions.
Sincerely,
FirstName LastNameSanjeev Redkar
Division of
Corporation Finance
Comapany NameApollomics Inc.
Office of Life
Sciences
April 12, 2024 Page 2
cc: Daniel Nussen, Esq.
FirstName LastName