SEC Comment Letter 0000000000-22-012889 to ZZLL INFORMATION TECHNOLOGY, INC (CIK 0001365357)
ZZLL INFORMATION TECHNOLOGY, INC (CIK 0001365357)
Date: Nov. 29, 2022 · CIK: 0001365357 · Accession: 0000000000-22-012889
AI Filing Summary & Sentiment
File numbers found in text: 000-52779
Referenced dates: October 18, 2022
Letter
United States securities and exchange commission logo November 29, 2022 Yanfei Tang Chief Executive Officer and Chief Financial Officer ZZLL Information Technology, Inc. Unit 1504, 15/F., Carnival Commercial Building 18 Java Road, North Point Hong Kong Re:ZZLL Information Technology, Inc. Form 10-K for Fiscal Year Ended December 31, 2021 Response dated October 18, 2022 File No. 000-52779 Dear Yanfei Tang: We have reviewed your October 18, 2022 response to our comment letter and have the following comment. Our comment, ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 22, 2022 letter. Response Letter dated October 18, 2022 General 1.We note your response to comment 4 and reissue. We note your intention to provide disclosures about the legal and operational risks associated with China-based companies in future filings. However, we request that you supplementally provide us with your proposed revised disclosures which addresses the full comment via correspondence. To the extent the China-based company Dear Issuer Letter requests disclosure on a prospectus cover page or prospectus summary, such disclosure should be provided in Item 1 of Form 10-K and, with respect to the discussion of the transfer of cash within the company, such disclosure should be provided in Item 7 of Form 10-K. Please note that we may have further comments upon review of the proposed revised disclosures.
FirstName LastNameYanfei Tang Comapany NameZZLL Information Technology, Inc. November 29, 2022 Page 2 FirstName LastName Yanfei Tang ZZLL Information Technology, Inc. November 29, 2022 Page 2 You may contact Patrick Kuhn at (202) 551-3308 or Theresa Brillant at (202) 551-3307 if you have questions regarding comments on the financial statements and related matters. Please contact Rucha Pandit at (202) 551-6022 or Donald Field at (202) 551-3680 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
November 29, 2022
Yanfei Tang
Chief Executive Officer and Chief Financial Officer
ZZLL Information Technology, Inc.
Unit 1504, 15/F., Carnival Commercial Building
18 Java Road, North Point Hong Kong
Re:ZZLL Information Technology, Inc.
Form 10-K for Fiscal Year Ended December 31, 2021
Response dated October 18, 2022
File No. 000-52779
Dear Yanfei Tang:
We have reviewed your October 18, 2022 response to our comment letter and have the
following comment. Our comment, ask you to provide us with information so we may better
understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
August 22, 2022 letter.
Response Letter dated October 18, 2022
General
1.We note your response to comment 4 and reissue. We note your intention to provide
disclosures about the legal and operational risks associated with China-based companies
in future filings. However, we request that you supplementally provide us with your
proposed revised disclosures which addresses the full comment via correspondence. To
the extent the China-based company Dear Issuer Letter requests disclosure on a
prospectus cover page or prospectus summary, such disclosure should be provided in Item
1 of Form 10-K and, with respect to the discussion of the transfer of cash within the
company, such disclosure should be provided in Item 7 of Form 10-K. Please note that
we may have further comments upon review of the proposed revised disclosures.
FirstName LastNameYanfei Tang
Comapany NameZZLL Information Technology, Inc.
November 29, 2022 Page 2
FirstName LastName
Yanfei Tang
ZZLL Information Technology, Inc.
November 29, 2022
Page 2
You may contact Patrick Kuhn at (202) 551-3308 or Theresa Brillant at (202) 551-3307 if
you have questions regarding comments on the financial statements and related matters. Please
contact Rucha Pandit at (202) 551-6022 or Donald Field at (202) 551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services