SEC Comment Letter 0000000000-24-005772 to BIMI Holdings Inc. (BIMI) (CIK 0001213660)
BIMI Holdings Inc. (BIMI) (CIK 0001213660)
Date: May 17, 2024 · CIK: 0001213660 · Accession: 0000000000-24-005772
AI Filing Summary & Sentiment
File numbers found in text: 001-34890
Letter
United States securities and exchange commission logo May 17, 2024 Tiewei Song Chief Executive Officer BIMI Holdings Inc. 9th Floor, Building 2 Chongqing Corporation Avenue Yuzhong District, Chongqing, P. R. China, 400010 Re:BIMI Holdings Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 Correspondence dated May 8, 2024 File No. 001-34890 Dear Tiewei Song: We have reviewed your May 8, 2024 response to our comment letter and have the following comment(s). 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 March 7, 2024 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 Regulation of Overseas Listing, page 19 1.Please further revise your disclosure to affirmatively state whether the holding company and its subsidiaries are covered by permissions requirements from the CSRC. Clarify whether you relied upon an opinion of counsel in that determination, and if not, explain why. In this regard, your proposed disclosure only speaks to your subsidiaries, and it does not explicitly state if you have determined the regulations apply to the holding company and its subsidiaries or not.
FirstName LastNameTiewei Song Comapany NameBIMI Holdings Inc. May 17, 2024 Page 2 FirstName LastName Tiewei Song BIMI Holdings Inc. May 17, 2024 Page 2 Please contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at 202-551-3336 if you have questions regarding comments on the financial statements and related matters. Please contact Taylor Beech at 202-551-4515 or Mara Ransom at 202-551-3264 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Pang Zhang-Whitaker
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United States securities and exchange commission logo
May 17, 2024
Tiewei Song
Chief Executive Officer
BIMI Holdings Inc.
9th Floor, Building 2
Chongqing Corporation Avenue
Yuzhong District, Chongqing,
P. R. China, 400010
Re:BIMI Holdings Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
Correspondence dated May 8, 2024
File No. 001-34890
Dear Tiewei Song:
We have reviewed your May 8, 2024 response to our comment letter and have the
following comment(s).
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 March 7,
2024 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Regulation of Overseas Listing, page 19
1.Please further revise your disclosure to affirmatively state whether the holding company
and its subsidiaries are covered by permissions requirements from the CSRC. Clarify
whether you relied upon an opinion of counsel in that determination, and if not, explain
why. In this regard, your proposed disclosure only speaks to your subsidiaries, and it does
not explicitly state if you have determined the regulations apply to the holding company
and its subsidiaries or not.
FirstName LastNameTiewei Song
Comapany NameBIMI Holdings Inc.
May 17, 2024 Page 2
FirstName LastName
Tiewei Song
BIMI Holdings Inc.
May 17, 2024
Page 2
Please contact Nasreen Mohammed at 202-551-3773 or Adam Phippen at 202-551-3336
if you have questions regarding comments on the financial statements and related matters. Please
contact Taylor Beech at 202-551-4515 or Mara Ransom at 202-551-3264 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Pang Zhang-Whitaker