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UPLOAD Filing

111, Inc.
Date: July 24, 2025 · CIK: 0001738906 · Accession: 0000000000-25-007788

Financial Reporting Regulatory Compliance Internal Controls

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File numbers found in text: 001-38639

Date
July 24, 2025
Author
Division of
Form
UPLOAD
Company
111, Inc.

Letter

Re: 111, Inc. Form 20-F for Fiscal Year Ended December 31, 2024 File No. 001-38639 Dear Junling Liu:

July 24, 2025

Junling Liu Chief Executive Officer and Co-Chairman of the Board 111, Inc. 3-4/F, No. 295 ZuChongZhi Road Pudong New Area Shanghai, 201203 The People s Republic of China

We have reviewed your filing and have the following comment(s).

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.

Form 20-F for Fiscal Year Ended December 31, 2024 Consolidated Financial Statements Reports of Independent Registered Public Accounting Firm, page F-4

1. Please amend your Form 20-F to include an audit report that covers the effects of the retrospective adjustments related to basis of presentation and segment reporting discussed in Note 2(a) and 2(ad) to the financial statements. Refer to PCAOB Staff Questions and Answers on Adjustments to Prior-Period Financial Statements Audited by a Predecessor Auditor, PCAOB AS 3105.54 through .58 and PCAOB AS 3110.06 through .07, as applicable. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. July 24, 2025 Page 2

Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at 202-551-3769 if you have any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 July 24, 2025

Junling Liu
Chief Executive Officer and Co-Chairman of the Board
111, Inc.
3-4/F, No. 295 ZuChongZhi Road
Pudong New Area
Shanghai, 201203
The People s Republic of China

 Re: 111, Inc.
 Form 20-F for Fiscal Year Ended December 31, 2024
 File No. 001-38639
Dear Junling Liu:

 We have reviewed your filing and have the following comment(s).

 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.

Form 20-F for Fiscal Year Ended December 31, 2024
Consolidated Financial Statements
Reports of Independent Registered Public Accounting Firm, page F-4

1. Please amend your Form 20-F to include an audit report that covers the
effects of the
 retrospective adjustments related to basis of presentation and segment
reporting
 discussed in Note 2(a) and 2(ad) to the financial statements. Refer to
PCAOB Staff
 Questions and Answers on Adjustments to Prior-Period Financial
Statements Audited
 by a Predecessor Auditor, PCAOB AS 3105.54 through .58 and PCAOB AS
3110.06
 through .07, as applicable.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.
 July 24, 2025
Page 2

 Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>