SEC Comment Letter 0000000000-23-009887 to NETWORK CN INC (NWCN) (CIK 0000934796)
NETWORK CN INC (NWCN) (CIK 0000934796)
Date: Sept. 7, 2023 · CIK: 0000934796 · Accession: 0000000000-23-009887
AI Filing Summary & Sentiment
File numbers found in text: 000-30264
Letter
United States securities and exchange commission logo September 7, 2023 Shirley Cheng Chief Financial Officer Network CN Inc. Unit 705B, 7th Floor New East Ocean Centre 9 Science Museum Road TST, KLN, Hong Kong Re:Network CN Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Response Dated August 17, 2023 File No. 000-30264 Dear Shirley Cheng: We have reviewed your August 17, 2023 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our August 4, 2023 letter. Form 10-K for Fiscal Year Ended December 31, 2022 Item I. Business, page 1 1.We note your response to comment 3 and reissue in part. We note your disclosure that the SAIC appears to have informed you that you "are not required to obtain the Advertising Operation Permit" and that as a result, you "are not required to obtain permit or approval from Chinese governing authorities to operate, other than [the] business license." As it appears that you have not relied on an opinion of counsel in coming to the conclusion that you are not required to obtain any other permits or approvals from Chinese authorities to operate, please revise your disclosure to explicitly state that you did not rely upon an opinion of counsel.
FirstName LastNameShirley Cheng Comapany NameNetwork CN Inc. September 7, 2023 Page 2 FirstName LastName Shirley Cheng Network CN Inc. September 7, 2023 Page 2 2.We note your response to comment 4 and reissue in part. Please revise the cross- references accompanying the summary risk factors related to your operations in Hong Kong and China to specifically include the individual title of the relevant risk factor. In this regard, we note that the current cross-references use a general subsection heading versus the actual individual risk factor titles. Please contact Rucha Pandit at (202) 551-6022 or Donald Field at (202) 551-3680 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
September 7, 2023
Shirley Cheng
Chief Financial Officer
Network CN Inc.
Unit 705B, 7th Floor
New East Ocean Centre
9 Science Museum Road
TST, KLN, Hong Kong
Re:Network CN Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Response Dated August 17, 2023
File No. 000-30264
Dear Shirley Cheng:
We have reviewed your August 17, 2023 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our
August 4, 2023 letter.
Form 10-K for Fiscal Year Ended December 31, 2022
Item I. Business, page 1
1.We note your response to comment 3 and reissue in part. We note your disclosure that the
SAIC appears to have informed you that you "are not required to obtain the Advertising
Operation Permit" and that as a result, you "are not required to obtain permit or approval
from Chinese governing authorities to operate, other than [the] business license." As it
appears that you have not relied on an opinion of counsel in coming to the conclusion that
you are not required to obtain any other permits or approvals from Chinese authorities to
operate, please revise your disclosure to explicitly state that you did not rely upon an
opinion of counsel.
FirstName LastNameShirley Cheng
Comapany NameNetwork CN Inc.
September 7, 2023 Page 2
FirstName LastName
Shirley Cheng
Network CN Inc.
September 7, 2023
Page 2
2.We note your response to comment 4 and reissue in part. Please revise the cross-
references accompanying the summary risk factors related to your operations in Hong
Kong and China to specifically include the individual title of the relevant risk factor. In
this regard, we note that the current cross-references use a general subsection heading
versus the actual individual risk factor titles.
Please contact Rucha Pandit at (202) 551-6022 or Donald Field at (202) 551-3680 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services