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September 24, 2019
Michael Perry
Chief Executive Officer
Avita Medical Limited
Level 7, 330 Collins Street
Melbourne VIC 3000 Australia
Re: Avita Medical Limited
Registration Statement on Form 20-F
Filed September 19, 2019
File No. 001-39059
Dear Dr. Perry:
We have reviewed your filing 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 and any amendment you may file in response
to these
comments, we may have additional comments. Unless we note otherwise, our
references to prior
comments are to comments in our September 18, 2019 letter.
Registration Statement on Form 20-F filed September 19, 2019
Key Information, page 2
1. We note your response to prior comment 8, and your disclosure added on
pages 4, 46 and
95 that the information in exhibit 15.1 should not be relied on as
indicative of actual
results for the year ended June 30, 2019. You may not disclaim
responsibility for your
disclosure; please revise to remove any implication to the contrary.
Also:
If the exhibit is not intended to be indicative of actual results,
clarify the purpose of
the report included as an exhibit, including what it is intended to
indicate.
Please be advised that you are responsible for considering whether
additional
disclosures of material information regarding your results are
required to make the
statements in your filing not misleading.
Michael Perry
FirstName LastNameMichael Perry
Avita Medical Limited
Comapany 24, 2019 Medical Limited
September NameAvita
September 24, 2019 Page 2
Page 2
FirstName LastName
General
2. Please ensure that your disclosure is current. We note for example
your September 17,
2019 press release.
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 Michael Fay at (202) 551-3812 or Brian Cascio,
Accounting Branch
Chief, at (202) 551-3676 if you have questions regarding comments on the
financial statements
and related matters. Please contact Tim Buchmiller at (202) 551-3635 or Russell
Mancuso,
Legal Branch Chief, at (202) 551-3617 with any other questions.
Sincerely,
Division of
Corporation Finance
Office of
Electronics and Machinery
cc: Christopher H. Cunningham, Esq.