SEC Comment Letter 0000000000-23-001720 to Uxin Ltd (UXIN)
Uxin Ltd
Date: Feb. 21, 2023 · CIK: 0001729173 · Accession: 0000000000-23-001720
AI Filing Summary & Sentiment
File numbers found in text: 001-38527
Letter
United States securities and exchange commission logo February 21, 2023 Feng Lin Chief Financial Officer Uxin Ltd 1&3/F, No. 12 Beitucheng East Road Chaoyang District, Beijing 100029 People’s Republic of China Re:Uxin Limited Form 20-F for the Year Ended March 31, 2022 Correspondence Filed January 9, 2023 File No. 001-38527 Dear Feng Lin: We have reviewed your January 9, 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 December 27, 2022 letter. Correspondence Filed January 9, 2023 Item 3. Key Information Permissions Required from the PRC Authorities, page 4 1.We note your response to comment 3. Please clarify whether you disclose each permission or approval that you and your subsidiaries are required to obtain from Chinese authorities to operate your business and to offer the securities being registered to foreign investors, and if not, please disclose each required approval.
FirstName LastNameFeng Lin Comapany NameUxin Ltd February 21, 2023 Page 2 FirstName LastName Feng Lin Uxin Ltd February 21, 2023 Page 2 Risk Factors You may experience difficulties in effecting service of legal process, enforcing foreign judgments or bringing actions..., page 28 2.We note your response to comment 4. Please further revise to identify the directors and senior executive officers whom you state reside within mainland China and Hong Kong for a significant portion of the time. Please contact Jennie Beysolow at 202-551-8108 or Taylor Beech at 202-551-4515 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Shu Du, Esq.
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United States securities and exchange commission logo
February 21, 2023
Feng Lin
Chief Financial Officer
Uxin Ltd
1&3/F, No. 12 Beitucheng East Road
Chaoyang District, Beijing 100029
People’s Republic of China
Re:Uxin Limited
Form 20-F for the Year Ended March 31, 2022
Correspondence Filed January 9, 2023
File No. 001-38527
Dear Feng Lin:
We have reviewed your January 9, 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
December 27, 2022 letter.
Correspondence Filed January 9, 2023
Item 3. Key Information
Permissions Required from the PRC Authorities, page 4
1.We note your response to comment 3. Please clarify whether you disclose each permission
or approval that you and your subsidiaries are required to obtain from Chinese authorities
to operate your business and to offer the securities being registered to foreign investors,
and if not, please disclose each required approval.
FirstName LastNameFeng Lin
Comapany NameUxin Ltd
February 21, 2023 Page 2
FirstName LastName
Feng Lin
Uxin Ltd
February 21, 2023
Page 2
Risk Factors
You may experience difficulties in effecting service of legal process, enforcing foreign
judgments or bringing actions..., page 28
2.We note your response to comment 4. Please further revise to identify the directors
and senior executive officers whom you state reside within mainland China and Hong
Kong for a significant portion of the time.
Please contact Jennie Beysolow at 202-551-8108 or Taylor Beech at 202-551-4515 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Shu Du, Esq.