SEC Comment Letter 0000000000-23-010831 to Tuniu Corp (TOUR) (CIK 0001597095) (TOUR)
Tuniu Corp (TOUR) (CIK 0001597095)
Date: Sept. 29, 2023 · CIK: 0001597095 · Accession: 0000000000-23-010831
AI Filing Summary & Sentiment
File numbers found in text: 001-36430
Letter
United States securities and exchange commission logo September 29, 2023 Anqiang Chen Financial Controller Tuniu Corporation Tuniu Building No. 32 Suningdadao, Xuanwu District Nanjing, Jiangsu Province 210042 The People’s Republic of China Re:Tuniu Corporation Form 20-F for the Fiscal Year Ended December 31, 2022 Response dated August 11, 2023 File No. 001-36430 Dear Anqiang Chen: We have reviewed your August 11, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 28, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 144 1.We note your response to comment 2. We also note your statement that after consulting with your PRC legal counsel and your further review of the employment profiles retained by you, you re-evaluated and determined that the three employee directors of your operating entities who serve on the Tuniu Chinese Communist Party Committee are not CCP officials. We note your intent to file an amendment to the 2022 Form 20-F to revise the disclosures accordingly. Since the three employee directors each have a CCP official title of secretary or deputy secretary of the Tuniu Chinese Communist Party Committee, please explain to us in detail how you reasonably concluded that they are not CCP
FirstName LastNameAnqiang Chen Comapany NameTuniu Corporation September 29, 2023 Page 2 FirstName LastName Anqiang Chen Tuniu Corporation September 29, 2023 Page 2 officials given their official titles, roles and responsibilities. Please contact Jimmy McNamara at 202-551-7349 or Jennifer Thompson at 202-551- 3737 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Haiping Li
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United States securities and exchange commission logo
September 29, 2023
Anqiang Chen
Financial Controller
Tuniu Corporation
Tuniu Building No. 32
Suningdadao, Xuanwu District
Nanjing, Jiangsu Province 210042
The People’s Republic of China
Re:Tuniu Corporation
Form 20-F for the Fiscal Year Ended December 31, 2022
Response dated August 11, 2023
File No. 001-36430
Dear Anqiang Chen:
We have reviewed your August 11, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 28, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 144
1.We note your response to comment 2. We also note your statement that after consulting
with your PRC legal counsel and your further review of the employment profiles retained
by you, you re-evaluated and determined that the three employee directors of your
operating entities who serve on the Tuniu Chinese Communist Party Committee are not
CCP officials. We note your intent to file an amendment to the 2022 Form 20-F to revise
the disclosures accordingly. Since the three employee directors each have a CCP official
title of secretary or deputy secretary of the Tuniu Chinese Communist Party Committee,
please explain to us in detail how you reasonably concluded that they are not CCP
FirstName LastNameAnqiang Chen
Comapany NameTuniu Corporation
September 29, 2023 Page 2
FirstName LastName
Anqiang Chen
Tuniu Corporation
September 29, 2023
Page 2
officials given their official titles, roles and responsibilities.
Please contact Jimmy McNamara at 202-551-7349 or Jennifer Thompson at 202-551-
3737 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Haiping Li