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UPLOAD Filing

Enlightify Inc.
Date: May 12, 2025 · CIK: 0000857949 · Accession: 0000000000-25-005036

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File numbers found in text: 001-34260

Referenced dates: April 1, 2025, August 29, 2024, October 1, 2024

Date
May 12, 2025
Author
Division of
Form
UPLOAD
Company
Enlightify Inc.

Letter

Re: Enlightify Inc. Form 10-K for the Fiscal Year Ended June 30, 2024 Response dated April 1, 2025 File No. 001-34260 Dear Yongcheng Yang:

May 12, 2025

Yongcheng Yang Chief Financial Officer Enlightify Inc. 3rd floor, Borough A, Block A. No. 181, South Taibai Road Xi an, Shaanxi Province, PRC 710065

We have reviewed your April 1, 2025 response to our comment letter and have the following comments.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our November 12, 2024 letter.

Form 10-K for the Fiscal Year Ended June 30, 2024 Part I, Item 1. Business, page 1

1. We note your response to comment 1, including that you undertake to add the disclosures in Appendix A of your response letter dated April 1, 2025 to the section entitled Business, immediately following the subsection titled Cash Flows through Our Organization in future filings. Please amend Part I, Item 1, "Business" of your Form 10-K for the fiscal year ended June 30, 2024 to include the disclosures in Appendix A. In this regard, we note your responses to comments one and two in your letter dated August 29, 2024, which undertook to update Part I, Item 1, Business in future annual reports on Form 10-K to include this disclosure, but we were unable to find this disclosure in your subsequently filed Exchange Act reports. 2. We note your response to comment 2 confirming that, in future filings, you will quantify any cash flows and transfers of other assets by type that have occurred May 12, 2025 Page 2

between the holding company, its subsidiaries, and the consolidated VIEs, and the direction of transfer. We also note your disclosure included in appendix E to your response letter dated October 1, 2024, which discussed loans and payments between you, your subsidiaries and the VIE, and which is not included in your subsequently filed annual report. Please advise why this disclosure was not included in your discussion of cash flows on page 4 of your Form 10-K for the fiscal year ended June 30, 2024, and revise to include this disclosure. Part I, Item 1C. Cybersecurity., page 40

3. We note your response to comment 3 that you undertake to add certain cybersecurity disclosures included in your response letter dated April 1, 2025 in future filings. Please amend your Form 10-K for the fiscal year ended June 30, 2024 to include these disclosures. Please contact Christie Wong at 202-551-3684 or Michael Fay at 202-551-3812 if you have questions regarding comments on the financial statements and related matters. Please contact Juan Grana at 202-551-6034 or Katherine Bagley at 202-551-2545 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Industrial
Applications and
Services
cc: Robert Zepfel, Esq.

Show Raw Text
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<TEXT>
 May 12, 2025

Yongcheng Yang
Chief Financial Officer
Enlightify Inc.
3rd floor, Borough A, Block A. No. 181, South Taibai Road
Xi an, Shaanxi Province, PRC 710065

 Re: Enlightify Inc.
 Form 10-K for the Fiscal Year Ended June 30, 2024
 Response dated April 1, 2025
 File No. 001-34260
Dear Yongcheng Yang:

 We have reviewed your April 1, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
November 12, 2024 letter.

Form 10-K for the Fiscal Year Ended June 30, 2024
Part I, Item 1. Business, page 1

1. We note your response to comment 1, including that you undertake to add
the
 disclosures in Appendix A of your response letter dated April 1, 2025 to
the section
 entitled Business, immediately following the subsection titled
Cash Flows through
 Our Organization in future filings. Please amend Part I, Item 1,
"Business" of
 your Form 10-K for the fiscal year ended June 30, 2024 to include the
disclosures in
 Appendix A. In this regard, we note your responses to comments one and
two in your
 letter dated August 29, 2024, which undertook to update Part I, Item 1,
 Business in
 future annual reports on Form 10-K to include this disclosure, but we
were unable to
 find this disclosure in your subsequently filed Exchange Act reports.
2. We note your response to comment 2 confirming that, in future filings,
you will
 quantify any cash flows and transfers of other assets by type that have
occurred
 May 12, 2025
Page 2

 between the holding company, its subsidiaries, and the consolidated
VIEs, and the
 direction of transfer. We also note your disclosure included in appendix
E to your
 response letter dated October 1, 2024, which discussed loans and
payments between
 you, your subsidiaries and the VIE, and which is not included in your
subsequently
 filed annual report. Please advise why this disclosure was not included
in your
 discussion of cash flows on page 4 of your Form 10-K for the fiscal year
ended June
 30, 2024, and revise to include this disclosure.
Part I, Item 1C. Cybersecurity., page 40

3. We note your response to comment 3 that you undertake to add certain
cybersecurity
 disclosures included in your response letter dated April 1, 2025 in
future
 filings. Please amend your Form 10-K for the fiscal year ended June 30,
2024 to
 include these disclosures.
 Please contact Christie Wong at 202-551-3684 or Michael Fay at
202-551-3812 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Juan Grana at 202-551-6034 or Katherine Bagley at 202-551-2545 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Robert Zepfel, Esq.
</TEXT>
</DOCUMENT>