SEC Comment Letter 0000000000-23-012622 to LightInTheBox Holding Co., Ltd. (LITB)
LightInTheBox Holding Co., Ltd.
Date: Nov. 17, 2023 · CIK: 0001523836 · Accession: 0000000000-23-012622
AI Filing Summary & Sentiment
File numbers found in text: 001-35942
Letter
United States securities and exchange commission logo November 17, 2023 Yuanjun Ye Chief Financial Officer LightInTheBox Holding Co., Ltd. 51 Tai Seng Avenue #05-02B/C, Pixel Red Singapore 533941 Re:LightInTheBox Holding Co., Ltd. Form 20-F for Fiscal Year Ended December 31, 2022 Response dated September 28, 2023 File No. 001-35942 Dear Yuanjun Ye: We have reviewed your September 28, 2023 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our September 19, 2023 letter. Form 20-F for Fiscal Year Ended December 31, 2022 General 1.We note your response to prior comment 1. In order to clarify the scope of your review, please supplementally describe the steps you have taken to confirm that none of the members of your board or the boards of your consolidated foreign operating entities are officials of the Chinese Communist Party. For instance, please tell us how the board members’ current or prior memberships on, or affiliations with, committees of the Chinese Communist Party factored into your determination. In addition, please tell us whether you have relied upon third party certifications such as affidavits as the basis for your disclosure.
FirstName LastNameYuanjun Ye Comapany NameLightInTheBox Holding Co., Ltd. November 17, 2023 Page 2 FirstName LastName Yuanjun Ye LightInTheBox Holding Co., Ltd. November 17, 2023 Page 2
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at 202-551-3377 with any other questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Yu Wang
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United States securities and exchange commission logo
November 17, 2023
Yuanjun Ye
Chief Financial Officer
LightInTheBox Holding Co., Ltd.
51 Tai Seng Avenue
#05-02B/C, Pixel Red
Singapore 533941
Re:LightInTheBox Holding Co., Ltd.
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated September 28, 2023
File No. 001-35942
Dear Yuanjun Ye:
We have reviewed your September 28, 2023 response to our comment letter 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. Unless
we note otherwise, any references to prior comments are to comments in our September 19,
2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
General
1.We note your response to prior comment 1. In order to clarify the scope of your review,
please supplementally describe the steps you have taken to confirm that none of the
members of your board or the boards of your consolidated foreign operating entities are
officials of the Chinese Communist Party. For instance, please tell us how the board
members’ current or prior memberships on, or affiliations with, committees of the Chinese
Communist Party factored into your determination. In addition, please tell us whether you
have relied upon third party certifications such as affidavits as the basis for your
disclosure.
FirstName LastNameYuanjun Ye
Comapany NameLightInTheBox Holding Co., Ltd.
November 17, 2023 Page 2
FirstName LastName
Yuanjun Ye
LightInTheBox Holding Co., Ltd.
November 17, 2023
Page 2
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at 202-551-3377 with
any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Yu Wang