SEC Comment Letter 0000000000-23-005178 to Recon Technology, Ltd (RCON) (CIK 0001442620) (RCON)
Recon Technology, Ltd (RCON) (CIK 0001442620)
Date: May 15, 2023 · CIK: 0001442620 · Accession: 0000000000-23-005178
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File numbers found in text: 333-271547
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United States securities and exchange commission logo
May 15, 2023
Jia Liu
Chief Financial Officer
Recon Technology, Ltd
Room 601, Shui’an South Street
Chaoyang District, Beijing, 100012
People’s Republic of China
Re:Recon Technology, Ltd
Registration Statement on Form F-1
Filed May 1, 2023
File No. 333-271547
Dear Jia Liu:
We have limited our review of your registration statement to those issues we have
addressed in our comments. In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1 filed May 1, 2023
General
1.We note your cover page disclosure indicating that the CSRC recently published Trial
Measures that impose certain filing requirements for direct and indirect overseas listings
and offerings. Please disclose how, if at all, the Trial Measures apply to this transaction,
whether you and relevant parties to this transaction have complied with your obligations
under the Trial Measures, and the risks to investors of noncompliance.
FirstName LastNameJia Liu
Comapany NameRecon Technology, Ltd
May 15, 2023 Page 2
FirstName LastName
Jia Liu
Recon Technology, Ltd
May 15, 2023
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 Liz Packebusch, Staff Attorney, at (202) 551-8749 or Kevin Dougherty,
Staff Attorney, at (202) 551-3271 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Anthony W. Basch