SEC Comment Letter 0000000000-24-002206 to New Oriental Education & Technology Group Inc. (EDU, NWOEF) (CIK 0001372920) (EDU)
New Oriental Education & Technology Group Inc. (EDU, NWOEF) (CIK 0001372920)
Date: Feb. 27, 2024 · CIK: 0001372920 · Accession: 0000000000-24-002206
AI Filing Summary & Sentiment
File numbers found in text: 001-32993
Letter
United States securities and exchange commission logo February 27, 2024 Zhihui Yang Chief Financial 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, 2023 Response dated February 1, 2024 File No. 001-32993 Dear Zhihui Yang: We have reviewed your February 1, 2024 response to our comment letter and have the following comment. 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 January 18, 2024 letter. Form 20-F for Fiscal Year Ended May 31, 2023 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 168 1.We note your response to prior comment 2. For both your board and the boards of your consolidated foreign operating entities, please tell us how the board members’ current or prior memberships on, or affiliations with, committees of the Chinese Communist Party factored into your determination that none of the board members are officials of the Chinese Communist Party. In addition, please tell us in more detail how you considered the profile of Mr. Yu and, particularly, his role serving as Standing Committee Member of the Central Committee of the China Democratic League.
FirstName LastNameZhihui Yang Comapany NameNew Oriental Education & Technology Group Inc. February 27, 2024 Page 2 FirstName LastName Zhihui Yang New Oriental Education & Technology Group Inc. February 27, 2024 Page 2 Please contact Charles Guidry at 202-551-3621 or Jennifer Gowetski at 202-551-3401 with any other questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Haiping Li
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United States securities and exchange commission logo
February 27, 2024
Zhihui Yang
Chief Financial 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, 2023
Response dated February 1, 2024
File No. 001-32993
Dear Zhihui Yang:
We have reviewed your February 1, 2024 response to our comment letter and have the
following comment.
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 January 18,
2024 letter.
Form 20-F for Fiscal Year Ended May 31, 2023
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 168
1.We note your response to prior comment 2. For both your board and the boards of your
consolidated foreign operating entities, please tell us how the board members’ current or
prior memberships on, or affiliations with, committees of the Chinese Communist Party
factored into your determination that none of the board members are officials of the
Chinese Communist Party. In addition, please tell us in more detail how you considered
the profile of Mr. Yu and, particularly, his role serving as Standing Committee Member of
the Central Committee of the China Democratic League.
FirstName LastNameZhihui Yang
Comapany NameNew Oriental Education & Technology Group Inc.
February 27, 2024 Page 2
FirstName LastName
Zhihui Yang
New Oriental Education & Technology Group Inc.
February 27, 2024
Page 2
Please contact Charles Guidry at 202-551-3621 or Jennifer Gowetski at 202-551-3401
with any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Haiping Li