SEC Comment Letter 0000000000-23-012202 to Tuniu Corp (TOUR) (CIK 0001597095) (TOUR)
Tuniu Corp (TOUR) (CIK 0001597095)
Date: Nov. 7, 2023 · CIK: 0001597095 · Accession: 0000000000-23-012202
AI Filing Summary & Sentiment
File numbers found in text: 001-36430
Letter
United States securities and exchange commission logo November 7, 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 October 26, 2023 File No. 001-36430 Dear Anqiang Chen: We have reviewed your October 26, 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 29, 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 prior comment 1. As previously requested, please explain to us in detail how you reasonably concluded that the three employee directors who have a CCP official title of secretary or deputy secretary of the Tuniu Chinese Communist Party Committee are not CCP officials given their official titles, roles and responsibilities. In doing so, please describe in detail the roles and responsibilities corresponding to each official title. Please contact Jennifer Thompson at 202-551-3737 or Andrew Mew at 202-551-3377 with any other questions.
FirstName LastNameAnqiang Chen Comapany NameTuniu Corporation November 7, 2023 Page 2 FirstName LastName Anqiang Chen Tuniu Corporation November 7, 2023 Page 2 Sincerely, Division of Corporation Finance Disclosure Review Program cc: Haiping Li
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United States securities and exchange commission logo
November 7, 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 October 26, 2023
File No. 001-36430
Dear Anqiang Chen:
We have reviewed your October 26, 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 29, 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 prior comment 1. As previously requested, please explain to us
in detail how you reasonably concluded that the three employee directors who have a CCP
official title of secretary or deputy secretary of the Tuniu Chinese Communist Party
Committee are not CCP officials given their official titles, roles and responsibilities. In
doing so, please describe in detail the roles and responsibilities corresponding to each
official title.
Please contact Jennifer Thompson at 202-551-3737 or Andrew Mew at 202-551-3377
with any other questions.
FirstName LastNameAnqiang Chen
Comapany NameTuniu Corporation
November 7, 2023 Page 2
FirstName LastName
Anqiang Chen
Tuniu Corporation
November 7, 2023
Page 2
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Haiping Li