View:
United States securities and exchange commission logo
August 23, 2022
Leo Li
Chief Financial Officer
Burning Rock Biotech Limited
No.5 Xingdao Ring Road North, International Bio Island
Guangzhou, Guangdong
People s Republic of China
Re: Burning Rock
Biotech Limited
Form 20-F for the
fiscal year ended December 31, 2021
Filed April 29,
2022
File No. 001-39316
Dear Mr. Li:
We have limited our review of your filing to the financial
statements and related
disclosures 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 to these comments, we may have additional comments.
Form 20-F for the fiscal year ended December 31, 2021
Item 5. Operating and Financial Review and Prospects, page 95
Results of Operations, page 108
Year Ended December 31, 2021 Compared to Year Ended December 31, 2020,
page 109
1. We note from page F-41
that your CODM assesses the performance of the operating
segments based on "the
measures of revenues, cost of revenue and gross profit by central
laboratory business,
in-hospital business and pharma research and development services."
Please provide a more
robust analysis of gross profit by segment for the periods
presented as required
by Item 303(b)(2)(ii) of Regulation S-K, especially considering that,
for 2021 for example,
gross profit increased 16.0% while gross margin decreased 1.3%.
Leo Li
Burning Rock Biotech Limited
August 23, 2022
Page 2
3 Segment Reporting, page F-41
2. We note the amounts shown in parentheses as revenue from services
attributable to the in-
hospital business/segment for each of the three periods presented.
Please clarify what
these parenthetical amounts represent, e.g., an expense instead of
revenue. Explain how, if
at all, net recognition of these services as described on page F-30
has resulted in these
negative amounts.
In closing, 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 Jenn Do at (202) 551-3743 or Daniel Gordon at (202)
551-3486 with
any questions.
FirstName LastNameLeo Li Sincerely,
Comapany NameBurning Rock Biotech Limited
Division of
Corporation Finance
August 23, 2022 Page 2 Office of Life
Sciences
FirstName LastName