SEC Comment Letter 0000000000-24-006656 to VNET Group, Inc. (VNET) (CIK 0001508475) (VNET)
VNET Group, Inc. (VNET) (CIK 0001508475)
Date: June 10, 2024 · CIK: 0001508475 · Accession: 0000000000-24-006656
AI Filing Summary & Sentiment
File numbers found in text: 001-35126
Letter
United States securities and exchange commission logo June 10, 2024 Qiyu Wang Chief Financial Officer VNET Group, Inc. Guanjie Building Southeast 1st Floor, 10# Jiuxianqiao East Road Chaoyang District Beijing, 100016 The People's Republic of China Re:VNET Group, Inc. Form 20-F for the Year Ended December 31, 2023 Filed April 26, 2024 File No. 001-35126 Dear Qiyu Wang: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). 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. Form 20-F for the Year Ended December 31, 2023 Introduction, page 1 1.We note that you have excluded Hong Kong and Macau from your definition of "China" or "PRC" for the purpose of your annual report, yet it appears that you have Hong Kong subsidiaries. Please remove the exclusion of Hong Kong and Macau from such definition and clarify that the legal and operational risks associated with operating in China also apply to operations in Hong Kong/Macau. In this regard, ensure that your disclosure does not narrow risks related to operating in the PRC to mainland China only. Where appropriate, you may describe PRC law and then explain how law in Hong Kong/Macau differs from PRC law and describe any risks and consequences to the Company associated with those laws.
FirstName LastNameQiyu Wang Comapany NameVNET Group, Inc. June 10, 2024 Page 2 FirstName LastName Qiyu Wang VNET Group, Inc. June 10, 2024 Page 2 Financial Information Related to the VIEs and Parent, page 13 2.In future filings please label your tables as "Condensed Consolidating" instead of "Condensed Consolidated." In closing, 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. Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-551- 3361 with any questions. Sincerely, Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
June 10, 2024
Qiyu Wang
Chief Financial Officer
VNET Group, Inc.
Guanjie Building Southeast 1st Floor, 10# Jiuxianqiao East Road
Chaoyang District
Beijing, 100016
The People's Republic of China
Re:VNET Group, Inc.
Form 20-F for the Year Ended December 31, 2023
Filed April 26, 2024
File No. 001-35126
Dear Qiyu Wang:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
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.
Form 20-F for the Year Ended December 31, 2023
Introduction, page 1
1.We note that you have excluded Hong Kong and Macau from your definition of "China"
or "PRC" for the purpose of your annual report, yet it appears that you have Hong Kong
subsidiaries. Please remove the exclusion of Hong Kong and Macau from such definition
and clarify that the legal and operational risks associated with operating in China also
apply to operations in Hong Kong/Macau. In this regard, ensure that your disclosure does
not narrow risks related to operating in the PRC to mainland China only. Where
appropriate, you may describe PRC law and then explain how law in Hong Kong/Macau
differs from PRC law and describe any risks and consequences to the Company associated
with those laws.
FirstName LastNameQiyu Wang
Comapany NameVNET Group, Inc.
June 10, 2024 Page 2
FirstName LastName
Qiyu Wang
VNET Group, Inc.
June 10, 2024
Page 2
Financial Information Related to the VIEs and Parent, page 13
2.In future filings please label your tables as "Condensed Consolidating" instead of
"Condensed Consolidated."
In closing, 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.
Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage at 202-551-
3361 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology