UPLOAD Filing
111, Inc.
Date: Aug. 11, 2025 · CIK: 0001738906 · Accession: 0000000000-25-008376
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38639
Letter
Re: 111, Inc. Form 20-F for Fiscal Year Ended December 31, 2024 Response dated August 6, 2025 File No. 001-38639 Dear Junling Liu:
August 11, 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 August 6, 2025 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our July 24, 2025 letter.
Form 20-F for Fiscal Year Ended December 31, 2024 Reports of Independent Registered Public Accounting Firm, page F-4
1. We read your response to prior comment 1. Please amend your Form 20-F to include an audit report, either from your successor auditor or your predecessor auditor, 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. August 11, 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 <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> August 11, 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 Response dated August 6, 2025 File No. 001-38639 Dear Junling Liu: We have reviewed your August 6, 2025 response to our comment letter 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. Unless we note otherwise, any references to prior comments are to comments in our July 24, 2025 letter. Form 20-F for Fiscal Year Ended December 31, 2024 Reports of Independent Registered Public Accounting Firm, page F-4 1. We read your response to prior comment 1. Please amend your Form 20-F to include an audit report, either from your successor auditor or your predecessor auditor, 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. August 11, 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>