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UPLOAD Filing

Yueda Digital Holding
Date: July 16, 2025 · CIK: 0001413745 · Accession: 0000000000-25-007508

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File numbers found in text: 333-286235

Date
July 16, 2025
Author
Division of
Form
UPLOAD
Company
Yueda Digital Holding

Letter

Re: AirNet Technology Inc. Amendment No. 2 to Registration Statement on Form F-3 Filed July 11, 2025 File No. 333-286235 Dear Dan Shao:

July 16, 2025

Dan Shao Chief Executive Officer AirNet Technology Inc. Suite 301, No. 26 Dongzhimenwai Street Chaoyang District, Beijing 100027 The People s Republic of China

We have conducted a limited review of your registration statement and have the following comment(s).

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments.

Amendment No. 2 to Registration Statement on Form F-3 filed July 11, 2025 General

1. We note that you have entered into a share purchase agreement for the disposition of your air travel media network business, after which your only remaining operations will be cryptocurrency mining. Please tell us your consideration of providing pro forma financial statements in accordance with Article 11 of Regulation S-X to reflect the disposition. Refer to Item 5(b)(1) of Form F-3. July 16, 2025 Page 2

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

Please contact Rebekah Reed at 202-551-5332 or Joel Parker at 202-551-3651 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Joan Wu

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 16, 2025

Dan Shao
Chief Executive Officer
AirNet Technology Inc.
Suite 301, No. 26 Dongzhimenwai Street
Chaoyang District, Beijing 100027
The People s Republic of China

 Re: AirNet Technology Inc.
 Amendment No. 2 to Registration Statement on Form F-3
 Filed July 11, 2025
 File No. 333-286235
Dear Dan Shao:

 We have conducted a limited review of your registration statement and
have the
following comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Amendment No. 2 to Registration Statement on Form F-3 filed July 11, 2025
General

1. We note that you have entered into a share purchase agreement for the
disposition of
 your air travel media network business, after which your only remaining
operations
 will be cryptocurrency mining. Please tell us your consideration of
providing pro
 forma financial statements in accordance with Article 11 of Regulation
S-X to reflect
 the disposition. Refer to Item 5(b)(1) of Form F-3.
 July 16, 2025
Page 2

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Rebekah Reed at 202-551-5332 or Joel Parker at
202-551-3651 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Joan Wu
</TEXT>
</DOCUMENT>