SEC Comment Letter 0000000000-23-010477 to ATA Creativity Global (AACG) (CIK 0001420529) (AACG)
ATA Creativity Global (AACG) (CIK 0001420529)
Date: Sept. 22, 2023 · CIK: 0001420529 · Accession: 0000000000-23-010477
AI Filing Summary & Sentiment
File numbers found in text: 001-33910
Letter
United States securities and exchange commission logo September 22, 2023 Xiaofeng Ma Chief Executive Officer ATA Creativity Global c/o 1/F East Gate, Building No. 2, Jian Wai Soho No. 39 Dong San Huan Zhong Road Chao Yang District, Beijing 100022, China Re:ATA Creativity Global Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 001-33910 Dear Xiaofeng Ma: We have reviewed your September 15, 2023 response to our comment letter and have the following comment. In our comments, 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 August 31, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 121 1.We note your response to prior comment to 3. We also note that you identified Zhilei Tong as a member of the CCP but determined that he is not a CCP official. We also note from Item 6 that Mr. Tong is the chairman and CEO of COL Digital Publishing Group Co., Ltd. and from COL Digital Publishing Group Co., Ltd.'s company website he is currently listed as a Deputy to the People’s Congress in Beijing. Please explain to us his roles and responsibilities as a Deputy and how you consider them in your determination.
FirstName LastNameXiaofeng Ma Comapany NameATA Creativity Global September 22, 2023 Page 2 FirstName LastName Xiaofeng Ma ATA Creativity Global September 22, 2023 Page 2 Please contact Kyle Wiley at (202) 344-5791 or Andrew Mew at (202) 551-3377 with any other questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Ning Zhang
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United States securities and exchange commission logo
September 22, 2023
Xiaofeng Ma
Chief Executive Officer
ATA Creativity Global
c/o 1/F East Gate, Building No. 2, Jian Wai Soho
No. 39 Dong San Huan Zhong Road
Chao Yang District, Beijing 100022, China
Re:ATA Creativity Global
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-33910
Dear Xiaofeng Ma:
We have reviewed your September 15, 2023 response to our comment letter and have the
following comment. In our comments, 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
August 31, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 121
1.We note your response to prior comment to 3. We also note that you identified Zhilei
Tong as a member of the CCP but determined that he is not a CCP official. We also note
from Item 6 that Mr. Tong is the chairman and CEO of COL Digital Publishing Group
Co., Ltd. and from COL Digital Publishing Group Co., Ltd.'s company website he is
currently listed as a Deputy to the People’s Congress in Beijing. Please explain to us his
roles and responsibilities as a Deputy and how you consider them in your determination.
FirstName LastNameXiaofeng Ma
Comapany NameATA Creativity Global
September 22, 2023 Page 2
FirstName LastName
Xiaofeng Ma
ATA Creativity Global
September 22, 2023
Page 2
Please contact Kyle Wiley at (202) 344-5791 or Andrew Mew at (202) 551-3377 with
any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Ning Zhang