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SEC Comment Letter 0000000000-23-012026 to Autohome Inc. (ATHM) (CIK 0001527636) (ATHM)

Autohome Inc. (ATHM) (CIK 0001527636)
Date: Nov. 3, 2023 · CIK: 0001527636 · Accession: 0000000000-23-012026

AI Filing Summary & Sentiment

File numbers found in text: 001-36222

Referenced dates: July 25, 2023

Date
November 3, 2023
Author
Office of Technology
Form
UPLOAD
Company
Autohome Inc. (ATHM) (CIK 0001527636)

Letter

United States securities and exchange commission logo November 3, 2023 Quan Long Chief Executive Officer Autohome Inc. 18th Floor Tower B, CEC Plaza 3 Dan Ling Street Haidian District, Beijing 10080 The People's Republic of China Re:Autohome Inc. Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 001-36222 Dear Quan Long: We have reviewed your September 13, 2023 response to our comment letter and have the following comments. 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 August 29, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 General 1.We note your response to prior comment 1(c) regarding your proposed treatment of time deposits as cash for purposes of section 3(a)(1)(C) of the Investment Company Act of 1940, as amended (“Company Act”). Please tell us how the calculations in your response to prior comment 8, in your letter dated July 25, 2023, change if you were to treat such time deposits as investment securities for purposes of the Company Act. Also, tell us whether this change would affect your conclusion that the Company is not an investment company, as defined in the Company Act.

FirstName LastNameQuan Long Comapany NameAutohome Inc. November 3, 2023 Page 2 FirstName LastName Quan Long Autohome Inc. November 3, 2023 Page 2 2.Please further revise the statement referenced in your response to prior comment 1(g) as follows, to the extent accurate: “Since its incorporation in 2013, Beijing Prbrownies Business has been primarily engaged in the aforementioned Beijing Prbrownies Business, and has not been primarily engaged in the business of investing, reinvesting, owning, holding, or trading in securities.” Please contact Megan Akst at 202-551-3407 or Christine Dietz at 202-551-3408 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Craig Yan Zeng

Show Raw Text
United States securities and exchange commission logo
November 3, 2023
Quan Long
Chief Executive Officer
Autohome Inc.
18th Floor Tower B, CEC Plaza
3 Dan Ling Street
Haidian District, Beijing 10080
The People's Republic of China
Re:Autohome Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 001-36222
Dear Quan Long:
            We have reviewed your September 13, 2023 response to our comment letter and have the
following comments.
            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 August 29, 2023
letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.We note your response to prior comment 1(c) regarding your proposed treatment of time
deposits as cash for purposes of section 3(a)(1)(C) of the Investment Company Act of
1940, as amended (“Company Act”). Please tell us how the calculations in your response
to prior comment 8, in your letter dated July 25, 2023, change if you were to treat such
time deposits as investment securities for purposes of the Company Act. Also, tell us
whether this change would affect your conclusion that the Company is not an investment
company, as defined in the Company Act.

 FirstName LastNameQuan Long
 Comapany NameAutohome Inc.
 November 3, 2023 Page 2
 FirstName LastName
Quan Long
Autohome Inc.
November 3, 2023
Page 2
2.Please further revise the statement referenced in your response to prior comment 1(g) as
follows, to the extent accurate: “Since its incorporation in 2013, Beijing Prbrownies
Business has been primarily engaged in the aforementioned Beijing Prbrownies Business,
and has not been primarily engaged in the business of investing, reinvesting, owning,
holding, or trading in securities.”
            Please contact Megan Akst at 202-551-3407 or Christine Dietz at 202-551-3408 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Craig Yan Zeng