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United States securities and exchange commission logo
November 24, 2021
Andrew Phillips
Chief Financial Officer
Helix Acquisition Corp
200 Clarendon Street
52nd floor
Boston, MA 02116
Re: Helix Acquisition
Corp
Form 10-K for the
Year Ended December 31, 2020
Filed March 31,
2021
Form 10-Q for the
Nine Months Ended September 30, 2021
Filed November 12,
2021
File No. 001-39630
Dear Dr. Phillips:
We have limited our review of your filings 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 10-Q for the Nine Months Ended September 30, 2021
Condensed Interim Financial Statements
Note 2--Revision of Previously Issued Financial Statements, page 8
1. You disclose in Note 2
that you will present this revision in a prospective manner in all
future filings and that
the previously issued Initial Public Offering Balance Sheet and
Form 10-Q s will not
be amended. Please address the following:
Please provide us
with your analysis under Staff Accounting Bulletin Topics 1:M and
1:N regarding this
revision.
As part of that
analysis, explain how you determined that retroactive revisions were
not appropriate in
this fact pattern.
Please explain why
you have not yet filed a Form 8-K addressing the requirements of
Andrew Phillips
Helix Acquisition Corp
November 24, 2021
Page 2
Item 4.02 of that form.
Please tell us your consideration that a material weakness in
your disclosure controls
and procedures and internal control over financial reporting does
not exist in light of
the revision.
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 Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 with
any questions.
FirstName LastNameAndrew Phillips Sincerely,
Comapany NameHelix Acquisition Corp
Division of
Corporation Finance
November 24, 2021 Page 2 Office of Life
Sciences
FirstName LastName