SEC Comment Letter 0000000000-23-001226 to Luokung Technology Corp. (LKCO) (CIK 0001487839)
Luokung Technology Corp. (LKCO) (CIK 0001487839)
Date: Feb. 6, 2023 · CIK: 0001487839 · Accession: 0000000000-23-001226
AI Filing Summary & Sentiment
File numbers found in text: 001-34738
Letter
United States securities and exchange commission logo February 6, 2023 Xuesong Song Chief Executive Officer Luokung Technology Corp. B9-8, Block B, SOHO Phase II, No. 9, Guanghua Road Chaoyang District, Beijing People’s Republic of China, 100020 Re:Luokung Technology Corp. Correspondence filed January 20, 2023 File No. 001-34738 Dear Xuesong Song: We have reviewed your January 20, 2023 response to our comment letter and have the following 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our December 6, 2022 letter. Form 20-F for the Fiscal Year Ended December 31, 2021 Item 3. Key Information, page 3 1.We note your response to prior comment 2. Please ensure your disclosures address how recent statements by China’s government have or may impact the company’s ability “to conduct its business, accept foreign investments, or list on a U.S. or other foreign exchange.” 2.We note your response to prior comment 5. Please expand your disclosure to specifically address whether or not any permissions and approvals are required to be obtained from Chinese authorities to offer securities. If you determine no permissions are required, provide an explanation as to whether you consulted counsel and, if not, why you did not consult counsel and why you do not need any permissions or approvals to offer securities.
FirstName LastNameXuesong Song Comapany NameLuokung Technology Corp. February 6, 2023 Page 2 FirstName LastName Xuesong Song Luokung Technology Corp. February 6, 2023 Page 2 D. Risk Factors, page 4 3.We note your response to prior comment 4. Please include a header to disclose which risk factors are related to doing business in China. You may contact Claire DeLabar, Staff Accountant at (202) 551-3349 or Robert Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Alexandra Barone, Staff Attorney at (202) 551-8816 or Mitchell Austin, Senior Staff Attorney at (202) 551- 3574 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Elizabeth Fei Chen
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United States securities and exchange commission logo
February 6, 2023
Xuesong Song
Chief Executive Officer
Luokung Technology Corp.
B9-8, Block B, SOHO Phase II, No. 9, Guanghua Road
Chaoyang District, Beijing
People’s Republic of China, 100020
Re:Luokung Technology Corp.
Correspondence filed January 20, 2023
File No. 001-34738
Dear Xuesong Song:
We have reviewed your January 20, 2023 response to our comment letter and have the
following 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
December 6, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Item 3. Key Information, page 3
1.We note your response to prior comment 2. Please ensure your disclosures address how
recent statements by China’s government have or may impact the company’s ability “to
conduct its business, accept foreign investments, or list on a U.S. or other foreign
exchange.”
2.We note your response to prior comment 5. Please expand your disclosure to specifically
address whether or not any permissions and approvals are required to be obtained from
Chinese authorities to offer securities. If you determine no permissions are required,
provide an explanation as to whether you consulted counsel and, if not, why you did not
consult counsel and why you do not need any permissions or approvals to offer securities.
FirstName LastNameXuesong Song
Comapany NameLuokung Technology Corp.
February 6, 2023 Page 2
FirstName LastName
Xuesong Song
Luokung Technology Corp.
February 6, 2023
Page 2
D. Risk Factors, page 4
3.We note your response to prior comment 4. Please include a header to disclose which risk
factors are related to doing business in China.
You may contact Claire DeLabar, Staff Accountant at (202) 551-3349 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters. Please contact Alexandra Barone,
Staff Attorney at (202) 551-8816 or Mitchell Austin, Senior Staff Attorney at (202) 551-
3574 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Elizabeth Fei Chen