SEC Comment Letter 0000000000-23-009229 to NaaS Technology Inc. (NAAS) (CIK 0001712178) (NAAS)
NaaS Technology Inc. (NAAS) (CIK 0001712178)
Date: Aug. 22, 2023 · CIK: 0001712178 · Accession: 0000000000-23-009229
AI Filing Summary & Sentiment
File numbers found in text: 001-38235
Letter
United States securities and exchange commission logo August 22, 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. Form 20-F for the Fiscal Year Ended December 31, 2022 Response dated August 9, 2023 File No. 001-38235 Dear Alex Wu: We have reviewed your August 9, 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. 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 July 28, 2023 letter. Response dated August 9, 2023 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 103 1.We note your response to comment 4. Item 16I(b) of Form 20-F states: “Also, any such identified foreign issuer that uses a variable-interest entity or any similar structure [emphasis added] that results in additional foreign entities being consolidated in the financial statements of the registrant is required to provide the below disclosures for itself and its consolidated foreign operating entity or entities.” Additionally, page 15 of our Release No. 34-93701, “Holding Foreign Companies Accountable Act Disclosure,” clarifies that a registrant should “look through a VIE or any structure [emphasis added] that results in additional foreign entities being consolidated in the financial statements of the registrant and provide the required disclosures about any consolidated operating
FirstName LastNameAlex Wu Comapany NameNaaS Technology Inc. August 22, 2023 Page 2 FirstName LastName Alex Wu NaaS Technology Inc. August 22, 2023 Page 2 company or companies in the relevant jurisdiction.” As previously requested, please provide us with the information required by Items 16I(b)(2), (b)(3) and (b)(5) for all of your consolidated foreign operating entities in your supplemental response. Please contact Austin Pattan at (202) 551-6756 or Jennifer Gowetski at (202) 551- 3401 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Shu Du
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United States securities and exchange commission logo
August 22, 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.
Form 20-F for the Fiscal Year Ended December 31, 2022
Response dated August 9, 2023
File No. 001-38235
Dear Alex Wu:
We have reviewed your August 9, 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.
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
July 28, 2023 letter.
Response dated August 9, 2023
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 103
1.We note your response to comment 4. Item 16I(b) of Form 20-F states: “Also, any such
identified foreign issuer that uses a variable-interest entity or any similar
structure [emphasis added] that results in additional foreign entities being consolidated in
the financial statements of the registrant is required to provide the below disclosures for
itself and its consolidated foreign operating entity or entities.” Additionally, page 15 of
our Release No. 34-93701, “Holding Foreign Companies Accountable Act Disclosure,”
clarifies that a registrant should “look through a VIE or any structure [emphasis added]
that results in additional foreign entities being consolidated in the financial statements of
the registrant and provide the required disclosures about any consolidated operating
FirstName LastNameAlex Wu
Comapany NameNaaS Technology Inc.
August 22, 2023 Page 2
FirstName LastName
Alex Wu
NaaS Technology Inc.
August 22, 2023
Page 2
company or companies in the relevant jurisdiction.” As previously requested, please
provide us with the information required by Items 16I(b)(2), (b)(3) and (b)(5) for all of
your consolidated foreign operating entities in your supplemental response.
Please contact Austin Pattan at (202) 551-6756 or Jennifer Gowetski at (202) 551-
3401 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Shu Du