SEC Comment Letter 0000000000-23-010811 to iClick Interactive Asia Group Ltd (ICLK) (CIK 0001697818) (AMBR)
iClick Interactive Asia Group Ltd (ICLK) (CIK 0001697818)
Date: Sept. 29, 2023 · CIK: 0001697818 · Accession: 0000000000-23-010811
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38313
Letter
United States securities and exchange commission logo September 29, 2023 Jian Tang Chief Executive Officer iClick Interactive Asia Group Ltd Prosperity Millennia Plaza, 663 King’s Road, Quarry Bay Hong Kong S.A.R. People’s Republic of China Re:iClick Interactive Asia Group Ltd Form 20-F for the Year Ended December 31, 2022 File No. 001-38313 Dear Jian Tang: We have reviewed your August 17, 2023 response to our comment letter 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 comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our August 1, 2023 letter. Form 20-F for Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 162 1.We note your response to prior comment 2. Item16I(b) of Form 20-F requires that you provide disclosures for yourself and your consolidated foreign operating entities, including variable interest entities or similar structures. Please amend your filing to disclose and quantify any ownership interests held by governmental entities, including any ownership interests held by state-owned enterprises, in all of your consolidated operating entities, including variable interest entities or similar structures. In particular, we note your response states that 8.0% of the equity interest in Anhui Myhayo is owned by Hefei New Economy Industry Development Investment Co., Ltd., which is a PRC state-owned enterprise.
FirstName LastNameJian Tang Comapany NameiClick Interactive Asia Group Ltd September 29, 2023 Page 2 FirstName LastName Jian Tang iClick Interactive Asia Group Ltd September 29, 2023 Page 2 Please contact Kyle Wiley at (202) 344-5791 or Jennifer Gowetski at (202) 551-3401 with any other questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Shuang Zhao
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United States securities and exchange commission logo
September 29, 2023
Jian Tang
Chief Executive Officer
iClick Interactive Asia Group Ltd
Prosperity Millennia Plaza, 663 King’s Road, Quarry Bay
Hong Kong S.A.R.
People’s Republic of China
Re:iClick Interactive Asia Group Ltd
Form 20-F for the Year Ended December 31, 2022
File No. 001-38313
Dear Jian Tang:
We have reviewed your August 17, 2023 response to our comment letter 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 comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
August 1, 2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 162
1.We note your response to prior comment 2. Item16I(b) of Form 20-F requires that you
provide disclosures for yourself and your consolidated foreign operating entities,
including variable interest entities or similar structures. Please amend your filing to
disclose and quantify any ownership interests held by governmental entities, including any
ownership interests held by state-owned enterprises, in all of your consolidated operating
entities, including variable interest entities or similar structures. In particular, we note
your response states that 8.0% of the equity interest in Anhui Myhayo is owned by Hefei
New Economy Industry Development Investment Co., Ltd., which is a PRC state-owned
enterprise.
FirstName LastNameJian Tang
Comapany NameiClick Interactive Asia Group Ltd
September 29, 2023 Page 2
FirstName LastName
Jian Tang
iClick Interactive Asia Group Ltd
September 29, 2023
Page 2
Please contact Kyle Wiley at (202) 344-5791 or Jennifer Gowetski at (202) 551-3401
with any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Shuang Zhao