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January 27, 2020
Ron Poliakine
Chief Executive Officer
Nano-X Imaging Ltd.
Communications Center
Neve Ilan, Israel 9085000
Re: Nano-X Imaging Ltd.
Draft Registration Statement on Form F-1/A
Filed January 14, 2020
CIK No. 0001795251
Dear Mr. Poliakine:
We have reviewed your amended 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.
Amended Draft Registration Statement filed January 14, 2020
Financial Statements
Note 6. Shareholders' Equity, page F-13
1. In response to comment 14, we note that since the $3,684,000 raised from
third-party
investors was sent directly to Six-Eye to pay for services, you
concluded that the
transactions should be presented as a non-cash financing activity in the
statement of cash
flows. Since the two transactions, the offering and the rendering of
services, represent a
financing activity and an operating activity, respectively, and the two
separate transactions
were with different parties, please further explain to us why you
believe that these two
transactions should not be shown gross in the statement of cash flows
instead of net. Refer
to ASC 230-10-45-7, 45-14, and 45-17 and 230-10-50-4.
Ron Poliakine
Nano-X Imaging Ltd.
January 27, 2020
Page 2
Note 8. Related Parties, page F-16
2. Please disclose, similar to your response to comment 14, that the
$3,684,000 raised from
third-party investors was sent directly to Six-Eye to pay for services
provided during the
year ended December 31, 2018 and for services to be provided during the
year ended
December 31, 2019.
You may contact Li Xiao at 202-551-4391 or Kate Tillan at 202-551-3604
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Paul Fischer at 202-551-3415 or Mary Beth Breslin at 202-551-3625 with any
other questions.
Sincerely,
FirstName LastNameRon Poliakine
Division of
Corporation Finance
Comapany NameNano-X Imaging Ltd.
Office of Life
Sciences
January 27, 2020 Page 2
cc: Andrea Nicolas, Esq.
FirstName LastName