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SEC Comment Letter for HiTek Global Inc. (HKIT) (CIK 0001742341) (BDAI) — Mar 6, 2020

HiTek Global Inc. (HKIT) (CIK 0001742341)
Date: March 6, 2020 · CIK: 0001742341 · Accession: 0000000000-20-002063

AI Filing Summary & Sentiment

Date
March 6, 2020
Author
/s/ Mara L. Ransom
Form
UPLOAD
Company
HiTek Global Inc. (HKIT) (CIK 0001742341)

Letter

Mail Stop 3561 March 6, 2020 Xiaoyang Huang Chief Executive Officer HiTek Global Inc. Unit 304, No. 30 Guanri Road, Siming District, Xiamen City, Fujian Province, People’s Republic of China

Re: HiTek Global Inc. Amendment No. 10 to Registration Statement on Form F-1 Filed February 28, 2020 File No. 333 -228498

Dear Ms. Huang :

We have reviewed your amended registration statements 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 this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments.

Overview, page 1

1. Given the recent Coronavirus outbreak in China and other countries, please tell us whether you expect the outbreak to have a material impact on your revenues in your current or future financial periods, and if so, disclose this in your filing. In addition, consider including a related risk factor.

Executive Compensation, page 62

2. Please update your executive compensation disclosure to include your recently completed fiscal y ear. Please refer to Item 6.B. of Form 20 -F.

Xiaoyang Huang HiTek Global Inc. March 6, 2020 Page 2

Please contact Scott Anderegg, Attorney Adviser, at (202) 551 -3342, or me at (202) 551 - 3720 if you have questions regarding the comments.

Sincerely,
/s/ Mara L. Ransom

Show Raw Text
Mail Stop 3561
March 6, 2020

Xiaoyang Huang
Chief Executive Officer
HiTek Global Inc.
Unit 304, No. 30 Guanri Road, Siming District,
Xiamen City, Fujian Province, People’s Republic of China

Re: HiTek Global Inc.
Amendment No. 10  to Registration Statement on Form F-1
Filed February 28, 2020
  File No. 333 -228498

Dear Ms. Huang :

We have reviewed your amended registration statements  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 this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

Overview, page 1

1. Given the recent Coronavirus outbreak in China and other countries, please tell us
whether you expect the outbreak to have a material impact on your revenues in your
current or future financial periods, and if so, disclose this in your filing.  In addition,
consider including a related risk factor.

Executive Compensation, page 62

2. Please update your executive compensation disclosure to include your recently completed
fiscal y ear.  Please refer to Item 6.B. of Form 20 -F.

Xiaoyang Huang
HiTek Global Inc.
March 6, 2020
Page 2

 Please contact Scott Anderegg, Attorney Adviser, at (202) 551 -3342, or me at (202) 551 -
3720 if you have questions regarding the comments.

Sincerely,

 /s/ Mara L. Ransom

 Mara L. Ransom
        Office Chief
        Office  of Trade and Services