SEC Comment Letter 0000000000-23-000168 to Ajia Innogroup Holdings, Ltd. (CIK 0001650739)
Ajia Innogroup Holdings, Ltd. (CIK 0001650739)
Date: Jan. 5, 2023 · CIK: 0001650739 · Accession: 0000000000-23-000168
AI Filing Summary & Sentiment
File numbers found in text: 333-206450
Letter
United States securities and exchange commission logo January 5, 2023 Wai Hing Lai Chief Financial Officer Ajia Innogroup Holdings, Ltd. 187 E. Warm Springs Road, Suite B307 Las Vegas, Nevada 89119 Re:Ajia Innogroup Holdings, Ltd. Form 10-K for Fiscal Year Ended June 30, 2022 Form 10-K for Fiscal Year Ended June 30, 2021 Response Dated November 10, 2022 File No. 333-206450 Dear Wai Hing Lai: We have limited our review of your filing to the financial statements and related disclosures 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. Form 10-K filed October 13, 2022 General 1.We note your response to comment 1 discussing restrictions related to your PRC Subsidiaries’ ability to pay dividends and discussing transactions that involved the transfer of cash. However, your disclosure does not reflect restrictions on you (or your Hong Kong subsidiary’s) ability to transfer cash or distribute earnings to the parent company and U.S. investors, along with the basis for this conclusion including how your experience validates such conclusions. Please revise to address such restrictions and provide cross-references to the consolidated financial statements. In closing, we remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameWai Hing Lai Comapany NameAjia Innogroup Holdings, Ltd. January 5, 2023 Page 2 FirstName LastName Wai Hing Lai Ajia Innogroup Holdings, Ltd. January 5, 2023 Page 2 Please contact Jennie Beysolow at 202-551-8108 or Mara Ransom at 202-551-3264 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Jessica M. Lockett, Esq.
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United States securities and exchange commission logo
January 5, 2023
Wai Hing Lai
Chief Financial Officer
Ajia Innogroup Holdings, Ltd.
187 E. Warm Springs Road, Suite B307
Las Vegas, Nevada 89119
Re:Ajia Innogroup Holdings, Ltd.
Form 10-K for Fiscal Year Ended June 30, 2022
Form 10-K for Fiscal Year Ended June 30, 2021
Response Dated November 10, 2022
File No. 333-206450
Dear Wai Hing Lai:
We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K filed October 13, 2022
General
1.We note your response to comment 1 discussing restrictions related to your PRC
Subsidiaries’ ability to pay dividends and discussing transactions that involved the transfer
of cash. However, your disclosure does not reflect restrictions on you (or your Hong Kong
subsidiary’s) ability to transfer cash or distribute earnings to the parent company and U.S.
investors, along with the basis for this conclusion including how your experience validates
such conclusions. Please revise to address such restrictions and provide cross-references
to the consolidated financial statements.
In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
FirstName LastNameWai Hing Lai
Comapany NameAjia Innogroup Holdings, Ltd.
January 5, 2023 Page 2
FirstName LastName
Wai Hing Lai
Ajia Innogroup Holdings, Ltd.
January 5, 2023
Page 2
Please contact Jennie Beysolow at 202-551-8108 or Mara Ransom at 202-551-3264 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Jessica M. Lockett, Esq.