SEC Comment Letter 0000000000-23-002082 to ADDENTAX GROUP CORP. (ATXG) (CIK 0001650101) (ATXG)
ADDENTAX GROUP CORP. (ATXG) (CIK 0001650101)
Date: March 1, 2023 · CIK: 0001650101 · Accession: 0000000000-23-002082
AI Filing Summary & Sentiment
File numbers found in text: 333-269409
Letter
United States securities and exchange commission logo March 1, 2023 Hong Zhida Chief Executive Officer ADDENTAX GROUP CORP. Kingkey 100, Block A, Room 4805 Luohu District, Shenzhen City China 518000 Re:ADDENTAX GROUP CORP. Amendment No. 1 to Registration Statement on Form S-1 Filed February 21, 2023 File No. 333-269409 Dear Hong Zhida: We have reviewed your amended registration statement 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 letter by amending your registration statement and providing the requested information. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February 14, 2023 letter. Amendment No. 1 to Registration Statement on Form S-1, filed February 21, 2023 Prospectus Summary PRC Limitation on Overseas Listing and Share Issuances, page 5 1.We note your response to comment 4 and reissue in part. Please disclose that you have not relied upon an opinion of counsel with respect to your conclusions that you do not need any additional permissions and approvals to operate your business, and disclose why you reached that decision (i.e., the explanation you provided in your response letter).
FirstName LastNameHong Zhida Comapany NameADDENTAX GROUP CORP. March 1, 2023 Page 2 FirstName LastName Hong Zhida ADDENTAX GROUP CORP. March 1, 2023 Page 2 Please contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Lawrence Venick
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United States securities and exchange commission logo
March 1, 2023
Hong Zhida
Chief Executive Officer
ADDENTAX GROUP CORP.
Kingkey 100, Block A, Room 4805
Luohu District, Shenzhen City
China 518000
Re:ADDENTAX GROUP CORP.
Amendment No. 1 to Registration Statement on Form S-1
Filed February 21, 2023
File No. 333-269409
Dear Hong Zhida:
We have reviewed your amended registration statement 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 letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to this comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our February 14, 2023 letter.
Amendment No. 1 to Registration Statement on Form S-1, filed February 21, 2023
Prospectus Summary
PRC Limitation on Overseas Listing and Share Issuances, page 5
1.We note your response to comment 4 and reissue in part. Please disclose that you have not
relied upon an opinion of counsel with respect to your conclusions that you do not need
any additional permissions and approvals to operate your business, and disclose why you
reached that decision (i.e., the explanation you provided in your response letter).
FirstName LastNameHong Zhida
Comapany NameADDENTAX GROUP CORP.
March 1, 2023 Page 2
FirstName LastName
Hong Zhida
ADDENTAX GROUP CORP.
March 1, 2023
Page 2
Please contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Lawrence Venick