SEC Comment Letter 0000000000-23-008739 to Meta Data Ltd (CIK 0001722380)
Meta Data Ltd (CIK 0001722380)
Date: Aug. 10, 2023 · CIK: 0001722380 · Accession: 0000000000-23-008739
AI Filing Summary & Sentiment
File numbers found in text: 001-38430
Referenced dates: July 21, 2023
Letter
United States securities and exchange commission logo August 10, 2023 Xiaoming Li Chief Executive Officer Meta Data Ltd Flat H 3/F, Haribest Industrial Building , 45-47 Au Pui Wan Street Sha Tin New Territories Hong Kong Re:Meta Data Ltd Annual Report on Form 20-F for the Fiscal Year Ended August 31, 2022 Filed December 30, 2022 Response dated July 21, 2023 File No. 001-38430 Dear Xiaoming Li: We have reviewed your July 21, 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 June 27, 2023 letter. Response Letter dated July 21, 2023 Transfers Between Our Company and Our Subsidiaries, page 2 1.We note your response to comment 3, as well as your revised disclosure that "[c]ash, not in the form of earnings distribution, was transferred between our Company, our subsidiaries and the former VIEs for the purpose of providing working capital between Meta Data, its subsidiaries, VIEs and its subsidiaries and WFOE." Please quantify the amounts and state the direction of transfer and any tax consequences. Tell us what your disclosure will look like.
FirstName LastNameXiaoming Li Comapany NameMeta Data Ltd August 10, 2023 Page 2 FirstName LastName Xiaoming Li Meta Data Ltd August 10, 2023 Page 2 You may contact Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 if you have questions regarding comments on the financial statements and related matters. Please contact Brian Fetterolf at 202-551-6613 or Jennifer López Molina at 202-551-3792 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Joan Wu
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United States securities and exchange commission logo
August 10, 2023
Xiaoming Li
Chief Executive Officer
Meta Data Ltd
Flat H 3/F, Haribest Industrial Building , 45-47 Au Pui Wan Street
Sha Tin New Territories
Hong Kong
Re:Meta Data Ltd
Annual Report on Form 20-F for the Fiscal Year Ended August 31, 2022
Filed December 30, 2022
Response dated July 21, 2023
File No. 001-38430
Dear Xiaoming Li:
We have reviewed your July 21, 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
June 27, 2023 letter.
Response Letter dated July 21, 2023
Transfers Between Our Company and Our Subsidiaries, page 2
1.We note your response to comment 3, as well as your revised disclosure that "[c]ash, not
in the form of earnings distribution, was transferred between our Company, our
subsidiaries and the former VIEs for the purpose of providing working capital between
Meta Data, its subsidiaries, VIEs and its subsidiaries and WFOE." Please quantify the
amounts and state the direction of transfer and any tax consequences. Tell us what your
disclosure will look like.
FirstName LastNameXiaoming Li
Comapany NameMeta Data Ltd
August 10, 2023 Page 2
FirstName LastName
Xiaoming Li
Meta Data Ltd
August 10, 2023
Page 2
You may contact Keira Nakada at 202-551-3659 or Linda Cvrkel at 202-551-3813 if you
have questions regarding comments on the financial statements and related matters. Please
contact Brian Fetterolf at 202-551-6613 or Jennifer López Molina at 202-551-3792 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Joan Wu