SEC Comment Letter 0000000000-23-002779 to NaaS Technology Inc. (NAAS) (CIK 0001712178) (NAAS)
NaaS Technology Inc. (NAAS) (CIK 0001712178)
Date: March 20, 2023 · CIK: 0001712178 · Accession: 0000000000-23-002779
AI Filing Summary & Sentiment
File numbers found in text: 001-38235
Letter
United States securities and exchange commission logo March 20, 2023 Alex Wu Chief Financial Officer NaaS Technology Inc. Newlink Center, Area G, Building 7 Huitong Times Square No.1 Yaojiayuan South Road, Chaoyang District Beijing, 100024, The People's Republic of China Re:NaaS Technology Inc. Shell Company Report on Form 20-F Response Dated February 14, 2023 File No. 001-38235 Dear Alex Wu: We have reviewed your March 8, 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 February 27, 2023 letter. Shell Company Report on Form 20-F Filed June 16, 2022 Dada Auto Inc. Combined Statements of Loss and Other Comprehensive Loss, page F-49 1.We note your response to comment 1. In future filings, please revise your results of operations discussion in MD&A to quantify the amounts of incentives in excess of related revenues that were reclassified to selling and marketing expenses for the periods presented and discuss the underlying reasons for changes, if material. You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters.
FirstName LastNameAlex Wu Comapany NameNaaS Technology Inc. March 20, 2023 Page 2 FirstName LastName Alex Wu NaaS Technology Inc. March 20, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
March 20, 2023
Alex Wu
Chief Financial Officer
NaaS Technology Inc.
Newlink Center, Area G, Building 7
Huitong Times Square
No.1 Yaojiayuan South Road, Chaoyang District
Beijing, 100024, The People's Republic of China
Re:NaaS Technology Inc.
Shell Company Report on Form 20-F
Response Dated February 14, 2023
File No. 001-38235
Dear Alex Wu:
We have reviewed your March 8, 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
February 27, 2023 letter.
Shell Company Report on Form 20-F Filed June 16, 2022
Dada Auto Inc.
Combined Statements of Loss and Other Comprehensive Loss, page F-49
1.We note your response to comment 1. In future filings, please revise your results of
operations discussion in MD&A to quantify the amounts of incentives in excess of related
revenues that were reclassified to selling and marketing expenses for the periods presented
and discuss the underlying reasons for changes, if material.
You may contact Stephen Kim at 202-551-3291 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters.
FirstName LastNameAlex Wu
Comapany NameNaaS Technology Inc.
March 20, 2023 Page 2
FirstName LastName
Alex Wu
NaaS Technology Inc.
March 20, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Trade & Services