SEC Comment Letter 0000000000-23-005744 to New Oriental Education & Technology Group Inc. (EDU, NWOEF) (CIK 0001372920) (EDU)
New Oriental Education & Technology Group Inc. (EDU, NWOEF) (CIK 0001372920)
Date: May 31, 2023 · CIK: 0001372920 · Accession: 0000000000-23-005744
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File numbers found in text: 001-32993
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United States securities and exchange commission logo
May 31, 2023
Chenggang Zhou
Chief Executive Officer
New Oriental Education & Technology Group Inc.
No. 6 Hai Dian Zhong Street
Haidian District
Beijing 100080
People’s Republic of China
Re:New Oriental Education & Technology Group Inc.
Form 20-F for Fiscal Year Ended May 31, 2022
Response Dated May 19, 2023
File No. 001-32993
Dear Chenggang Zhou:
We have reviewed your May 19, 2023 response to our comment letter and have the
following comment. In our comment, we may 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
May 5, 2023 letter.
Response Dated May 19, 2023
Item 3. Key Information, page 4
1.We note your response to comment 1 and reissue in part. We acknowledge your proposed
revised disclosure on page 3 of the filing, but please ensure that references to "our" refer
to New Oriental Education & Technology Group Co., Inc. rather than the VIEs. We note
your disclosure "and in the context of our operations..." where the "our" seems to refer to
both New Oriental Education & Technology Group Co., Inc. as well as the VIEs.
FirstName LastNameChenggang Zhou
Comapany NameNew Oriental Education & Technology Group Inc.
May 31, 2023 Page 2
FirstName LastName
Chenggang Zhou
New Oriental Education & Technology Group Inc.
May 31, 2023
Page 2
You may contact Suying Li at 202-551-3335 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Haiping Li