SEC Comment Letter 0000000000-23-010103 to Cheetah Mobile Inc. (CMCM) (CIK 0001597835) (CMCM)
Cheetah Mobile Inc. (CMCM) (CIK 0001597835)
Date: Sept. 12, 2023 · CIK: 0001597835 · Accession: 0000000000-23-010103
AI Filing Summary & Sentiment
File numbers found in text: 001-36427
Letter
United States securities and exchange commission logo September 12, 2023 Thomas Ren Chief Financial Officer Cheetah Mobile Inc. Building No. 11 Wandong Science and Technology Cultural Innovation Park No.7 Sanjianfangnanli, Chaoyang District Beijing 100024 People’s Republic of China Re:Cheetah Mobile Inc. Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 18, 2023 File No. 001-36427 Dear Thomas Ren: We have reviewed your September 1, 2023 response to our comment letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 11, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 General 1.You state in your response to prior comment 13 that “[n]o more than 45% of the value of Cheetah Mobile’s assets (exclusive of Government securities and cash items) consists of, and no more than 45% of its net income after taxes (for the last four fiscal quarters combined) is derived from securities other than those enumerated in Rule 3a-1(a)(1) – (4).” For this analysis, you state that such securities totaled RMB1,757,474, which appears to be derived from short term investments, prepayments and other current assets, net, due from related parties, net, and long-term investments. Based on the consolidated financial
FirstName LastNameThomas Ren Comapany NameCheetah Mobile Inc. September 12, 2023 Page 2 FirstName LastName Thomas Ren Cheetah Mobile Inc. September 12, 2023 Page 2 information provided in response to prior comment 14, it appears that “prepayments and other current assets, net” listed under “Assets" totaled RMB1,123,371, however, only RMB42,741 is recorded as securities for purposes of the calculation done for the 3a-1 analysis. Please provide us with a breakdown of the RMB1,123,371 in “prepayments and other current assets, net." 2.Please confirm that your analysis under Section 3(a)(1)(C) and the related financial statements were calculated and provided based on fair value (with value as defined in Section 2(a)(41) of the Investment Company Act of 1940). You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Sheryl (Xuyang) Zhang
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United States securities and exchange commission logo
September 12, 2023
Thomas Ren
Chief Financial Officer
Cheetah Mobile Inc.
Building No. 11
Wandong Science and Technology Cultural Innovation Park
No.7 Sanjianfangnanli, Chaoyang District
Beijing 100024
People’s Republic of China
Re:Cheetah Mobile Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 18, 2023
File No. 001-36427
Dear Thomas Ren:
We have reviewed your September 1, 2023 response to our comment letter and have the
following comments. In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 11, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.You state in your response to prior comment 13 that “[n]o more than 45% of the value of
Cheetah Mobile’s assets (exclusive of Government securities and cash items) consists of,
and no more than 45% of its net income after taxes (for the last four fiscal quarters
combined) is derived from securities other than those enumerated in Rule 3a-1(a)(1) –
(4).” For this analysis, you state that such securities totaled RMB1,757,474, which appears
to be derived from short term investments, prepayments and other current assets, net, due
from related parties, net, and long-term investments. Based on the consolidated financial
FirstName LastNameThomas Ren
Comapany NameCheetah Mobile Inc.
September 12, 2023 Page 2
FirstName LastName
Thomas Ren
Cheetah Mobile Inc.
September 12, 2023
Page 2
information provided in response to prior comment 14, it appears that “prepayments and
other current assets, net” listed under “Assets" totaled RMB1,123,371, however, only
RMB42,741 is recorded as securities for purposes of the calculation done for the 3a-1
analysis. Please provide us with a breakdown of the RMB1,123,371 in “prepayments and
other current assets, net."
2.Please confirm that your analysis under Section 3(a)(1)(C) and the related financial
statements were calculated and provided based on fair value (with value as defined in
Section 2(a)(41) of the Investment Company Act of 1940).
You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Sheryl (Xuyang) Zhang