SEC Comment Letter 0000000000-24-006469 to Xunlei Ltd (XNET) (CIK 0001510593) (XNET)
Xunlei Ltd (XNET) (CIK 0001510593)
Date: June 5, 2024 · CIK: 0001510593 · Accession: 0000000000-24-006469
AI Filing Summary & Sentiment
File numbers found in text: 001-35224
Letter
United States securities and exchange commission logo June 5, 2024 Naijiang (Eric) Zhou Chief Financial Officer Xunlei Ltd 3709 Baishi Road, Nanshan District, Shenzhen, 518000 The People’s Republic of China Re:Xunlei Ltd Form 20-F for the fiscal year ended December 31, 2023 File No. 001-35224 Dear Naijiang (Eric) Zhou: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. 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 fiscal year ended December 31, 2023 Consolidated Financial Statements Note 2. Summary of significant accounting policies (k) Goodwill, page F-19 1.We note that there has been a significant decline in your market capitalization over the last several years and that your market capitalization is substantially below your consolidated book value. We also note that you allocate goodwill to the company as a whole so it would appear you only have one reporting unit. Please explain to us how you concluded that your goodwill was not impaired as of December 31, 2023 and address the following: •Explain how you considered your market capitalization in determining the estimated fair value of your reporting unit; •Discuss how you considered the fact that your market capitalization is below book value in determining that goodwill has not been impaired; and •Compare the fair value of your reporting unit as of December 31, 2023, to the company’s market capitalization as of the same date and quantify and discuss the underlying reasons for the differences.
FirstName LastNameNaijiang (Eric) Zhou Comapany NameXunlei Ltd June 5, 2024 Page 2 FirstName LastName Naijiang (Eric) Zhou Xunlei Ltd June 5, 2024 Page 2 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 Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Haiping Li
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United States securities and exchange commission logo
June 5, 2024
Naijiang (Eric) Zhou
Chief Financial Officer
Xunlei Ltd
3709 Baishi Road, Nanshan District, Shenzhen, 518000
The People’s Republic of China
Re:Xunlei Ltd
Form 20-F for the fiscal year ended December 31, 2023
File No. 001-35224
Dear Naijiang (Eric) Zhou:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
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 fiscal year ended December 31, 2023
Consolidated Financial Statements
Note 2. Summary of significant accounting policies
(k) Goodwill, page F-19
1.We note that there has been a significant decline in your market capitalization over the last
several years and that your market capitalization is substantially below your consolidated
book value. We also note that you allocate goodwill to the company as a whole so it
would appear you only have one reporting unit. Please explain to us how you concluded
that your goodwill was not impaired as of December 31, 2023 and address the following:
•Explain how you considered your market capitalization in determining the estimated
fair value of your reporting unit;
•Discuss how you considered the fact that your market capitalization is below book
value in determining that goodwill has not been impaired; and
•Compare the fair value of your reporting unit as of December 31, 2023, to the
company’s market capitalization as of the same date and quantify and discuss the
underlying reasons for the differences.
FirstName LastNameNaijiang (Eric) Zhou
Comapany NameXunlei Ltd
June 5, 2024 Page 2
FirstName LastName
Naijiang (Eric) Zhou
Xunlei Ltd
June 5, 2024
Page 2
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 Chen Chen at 202-551-7351 or Christine Dietz at 202-551-3408 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Haiping Li