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SEC Comment Letter 0000000000-25-000423 to CHINA NATURAL RESOURCES INC (CHNR) (CIK 0000793628) (CHNR)

CHINA NATURAL RESOURCES INC (CHNR) (CIK 0000793628)
Date: Jan. 15, 2025 · CIK: 0000793628 · Accession: 0000000000-25-000423

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File numbers found in text: 333-278037

Date
January 14, 2025
Author
Not clearly detected
Form
UPLOAD
Company
CHINA NATURAL RESOURCES INC (CHNR) (CIK 0000793628)

Letter

January 14, 2025 Zhu Youyi Chief Financial Officer China Natural Resources, Inc. Room 2205, 22/F , West Tower, Shun Tak Centre 168-200 Connaught Road Central Sheung Wan, Hong Kong 011-852 - 2810-7205 Re:China Natural Resources, Inc. Post-Effective Amendment No. 1 to Form F-1 Filed December 31, 2024 File No. 333-278037 Dear Zhu Youyi: We have conducted a limited review of your post-effective amendment and have the following comments. 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. Post-Effective Amendment No. 1 to Form F-1 Compensation, page 95 1.Please revise your registration statement to include executive compensation disclosure for the fiscal year ended December 31, 2024. Refer to Part I, Item 4.a of Form F-1 and Part I, Item 6.B of Form 20-F. General We note that in your Forms 6-Ks filed on July 12, 2024 and January 6, 2025 you disclose that you received a notice of non-compliance with the Nasdaq requirements pertaining to the minimum bid price for listed stock pursuant to its rules for continued listing. Please revise the Summary to describe this notice and include disclosure in the 2.

January 14, 2025 Page 2 Risk Factor section describing the risks related to this notice and the risks of a potential delisting. 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 Claudia Rios at 202-551-8770 or Kevin Dougherty at 202-551-3271 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc:Richard Chang, Esq.

Show Raw Text
January 14, 2025
Zhu Youyi
Chief Financial Officer
China Natural Resources, Inc.
Room 2205, 22/F , West Tower, Shun Tak Centre
168-200 Connaught Road Central
Sheung Wan, Hong Kong
011-852 - 2810-7205
Re:China Natural Resources, Inc.
Post-Effective Amendment No. 1 to Form F-1
Filed December 31, 2024
File No. 333-278037
Dear Zhu Youyi:
            We have conducted a limited review of your post-effective amendment and have the
following comments.
            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.
Post-Effective Amendment No. 1 to Form F-1
Compensation, page 95
1.Please revise your registration statement to include executive compensation
disclosure for the fiscal year ended December 31, 2024. Refer to Part I, Item 4.a of
Form F-1 and Part I, Item 6.B of Form 20-F.
General
We note that in your Forms 6-Ks filed on July 12, 2024 and January 6, 2025 you
disclose that you received a notice of non-compliance with the Nasdaq requirements
pertaining to the minimum bid price for listed stock pursuant to its rules for continued
listing. Please revise the Summary to describe this notice and include disclosure in the 2.

January 14, 2025
Page 2
Risk Factor section describing the risks related to this notice and the risks of a
potential delisting.
            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 Claudia Rios at 202-551-8770 or Kevin Dougherty at 202-551-3271
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Richard Chang, Esq.