SEC Comment Letter 0000000000-23-011210 to Qutoutiao Inc. (QTTOY) (CIK 0001733298) (QTTOY)
Qutoutiao Inc. (QTTOY) (CIK 0001733298)
Date: Oct. 13, 2023 · CIK: 0001733298 · Accession: 0000000000-23-011210
AI Filing Summary & Sentiment
File numbers found in text: 001-38644
Letter
United States securities and exchange commission logo October 13, 2023 Eric Siliang Tan Chief Executive Officer Qutoutiao Inc. Building No. 2 , Shanghai Pudong Software Park 519 Yi De Road, Pudong New Area Shanghai 200124 People’s Republic of China Re:Qutoutiao Inc. Form 20-F for the Fiscal Year December 31, 2022 File No. 001-38644 Dear Eric Siliang Tan: We have reviewed your August 25, 2023 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our August 14, 2023 letter. Form 20-F for Fiscal Year Ended December 31, 2022 Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 152 1.As indicated in your response to prior comment 3, 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 company or companies in the relevant jurisdiction.” As previously requested, please
FirstName LastNameEric Siliang Tan Comapany NameQutoutiao Inc. October 13, 2023 Page 2 FirstName LastName Eric Siliang Tan Qutoutiao Inc. October 13, 2023 Page 2 provide us with the information required by Items 16I(b)(2) through (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 other questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Yi Gao
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United States securities and exchange commission logo
October 13, 2023
Eric Siliang Tan
Chief Executive Officer
Qutoutiao Inc.
Building No. 2 , Shanghai Pudong Software Park
519 Yi De Road, Pudong New Area
Shanghai 200124
People’s Republic of China
Re:Qutoutiao Inc.
Form 20-F for the Fiscal Year December 31, 2022
File No. 001-38644
Dear Eric Siliang Tan:
We have reviewed your August 25, 2023 response to our comment letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our August 14, 2023
letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 152
1.As indicated in your response to prior comment 3, 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
company or companies in the relevant jurisdiction.” As previously requested, please
FirstName LastNameEric Siliang Tan
Comapany NameQutoutiao Inc.
October 13, 2023 Page 2
FirstName LastName
Eric Siliang Tan
Qutoutiao Inc.
October 13, 2023
Page 2
provide us with the information required by Items 16I(b)(2) through (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 other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Yi Gao