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SEC Comment Letter 0000000000-23-007927 to Niu Technologies (NIU)

Niu Technologies
Date: July 25, 2023 · CIK: 0001744781 · Accession: 0000000000-23-007927

Financial Reporting Regulatory Compliance Internal Controls

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File numbers found in text: 001-38696

Referenced dates: July 10, 2023

Date
July 25, 2023
Author
Fion Wenjuan Zhou
Form
UPLOAD
Company
Niu Technologies

Letter

United States securities and exchange commission logo July 25, 2023 Fion Wenjuan Zhou Chief Financial Officer Niu Technologies No.1 Building, No. 195 Huilongguan East Road, Changping District, Beijing 102208 People’s Republic of China Re:Niu Technologies Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2022 Response letters dated July 10, 2023 and July 21, 2023 File No. 001-38696 Dear Fion Wenjuan Zhou: We have reviewed your July 10, 2023 and July 21, 2023 responses 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 June 26, 2023 letter. Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2022 Item 19. Exhibits, page 138 1.We have reviewed your response to prior comment 8. Please amend your December 31, 2022 Annual Report on Form 20-F in its entirety to properly include corrected Exhibits 13.1 and 13.2, as soon as practicable.

You may contact Beverly Singleton at (202) 551-3328 or Melissa Gilmore at (202) 551- 3777 if you have questions regarding comments on the financial statements and related matters. Contact Jennifer Thompson at (202) 551-3737 or Chris Dunham at (202) 551-3783 if you have any questions about comments related to your status as a Commission-Identified Issuer during your most recently completed fiscal year.

FirstName LastNameFion Wenjuan Zhou Comapany NameNiu Technologies July 25, 2023 Page 2 FirstName LastName Fion Wenjuan Zhou Niu Technologies July 25, 2023 Page 2 Sincerely, Division of Corporation Finance Office of Manufacturing

Show Raw Text
United States securities and exchange commission logo
July 25, 2023
Fion Wenjuan Zhou
Chief Financial Officer
Niu Technologies
No.1 Building, No. 195 Huilongguan East Road,
Changping District, Beijing 102208
People’s Republic of China
Re:Niu Technologies
Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2022
Response letters dated July 10, 2023 and July 21, 2023
File No. 001-38696
Dear Fion Wenjuan Zhou:
            We have reviewed your July 10, 2023 and July 21, 2023 responses 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
June 26, 2023 letter.
Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2022
Item 19. Exhibits, page 138
1.We have reviewed your response to prior comment 8.  Please amend your December 31,
2022 Annual Report on Form 20-F in its entirety to properly include corrected Exhibits
13.1 and 13.2, as soon as practicable.

            You may contact Beverly Singleton at (202) 551-3328 or Melissa Gilmore at (202) 551-
3777 if you have questions regarding comments on the financial statements and related
matters.  Contact Jennifer Thompson at (202) 551-3737 or Chris Dunham at (202) 551-3783 if
you have any questions about comments related to your status as a Commission-Identified Issuer
during your most recently completed fiscal year.

 FirstName LastNameFion Wenjuan Zhou
 Comapany NameNiu Technologies
 July 25, 2023 Page 2
 FirstName LastName
Fion Wenjuan Zhou
Niu Technologies
July 25, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing