SEC Comment Letter 0000000000-25-002231 to AI Era Corp. (AERA)
AI Era Corp.
Date: Feb. 27, 2025 · CIK: 0001605331 · Accession: 0000000000-25-002231
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-55979
Letter
February 27, 2025 Chiyuan Deng Chief Executive Officer, Chief Financial Officer and Director AB International Group Corp. 144 Main Street Mt. Kisco, NY 10549 Re:AB International Group Corp. Form 10-K for the Fiscal Year Ended August 31, 2024 File No. 000-55979 Dear Chiyuan Deng: We have reviewed your filing 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 the 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. Form 10-K for the fiscal year ended August 31, 2024 General 1.It appears that certain of your operations may be conducted in the PRC and/or Hong Kong. We note, for example, on November 27, 2023, the Company acquired mainland China copyrights of 4 movies from All In One Media Ltd. at price of $378,513. Please clarify for us the extent to which your operations are conducted in the PRC and/or Hong Kong. Please revise future filings, as applicable, to provide more specific and prominent disclosures about the legal and operational risks associated with China- based companies. For additional guidance, please see the Division of Corporation Finance's Sample Letter to China-Based Companies issued by the Staff in December 2021. To the extent the Sample Letter to China-Based Companies requests disclosure on the prospectus cover page or in the prospectus summary, please provide such disclosure at the beginning of Item 1 of Form 10-K; in addition, please include a discussion of the transfer of cash within the company in Item 7 of Form 10-K. In your response, provide us with the proposed revised disclosure you undertake to include in future filings. We remind you that the company and its management are responsible for the accuracy
February 27, 2025 Page 2 and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
Show Raw Text
February 27, 2025
Chiyuan Deng
Chief Executive Officer, Chief Financial Officer and Director
AB International Group Corp.
144 Main Street
Mt. Kisco, NY 10549
Re:AB International Group Corp.
Form 10-K for the Fiscal Year Ended August 31, 2024
File No. 000-55979
Dear Chiyuan Deng:
We have reviewed your filing 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
the 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.
Form 10-K for the fiscal year ended August 31, 2024
General
1.It appears that certain of your operations may be conducted in the PRC and/or Hong
Kong. We note, for example, on November 27, 2023, the Company acquired mainland
China copyrights of 4 movies from All In One Media Ltd. at price of $378,513. Please
clarify for us the extent to which your operations are conducted in the PRC and/or
Hong Kong. Please revise future filings, as applicable, to provide more specific and
prominent disclosures about the legal and operational risks associated with China-
based companies. For additional guidance, please see the Division of Corporation
Finance's Sample Letter to China-Based Companies issued by the Staff in December
2021. To the extent the Sample Letter to China-Based Companies requests disclosure
on the prospectus cover page or in the prospectus summary, please provide such
disclosure at the beginning of Item 1 of Form 10-K; in addition, please include a
discussion of the transfer of cash within the company in Item 7 of Form 10-K. In your
response, provide us with the proposed revised disclosure you undertake to include in
future filings.
We remind you that the company and its management are responsible for the accuracy
February 27, 2025
Page 2
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
Please contact Babette Cooper at 202-551-3396 or Jennifer Monick at 202-551-3295
if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction