SEC Comment Letter 0000000000-23-012464 to Yunji Inc. (YJ)
Yunji Inc.
Date: Nov. 14, 2023 · CIK: 0001759614 · Accession: 0000000000-23-012464
AI Filing Summary & Sentiment
File numbers found in text: 001-38877
Letter
United States securities and exchange commission logo November 14, 2023 Peng Zhang Vice President of Finance Yunji Inc. 15/F, South Building Hipark Phase 2, Xiaoshan District Hangzhou, Zhejiang, 310000 People’s Republic of China Re:Yunji Inc. Form 20-F for Fiscal Year Ended December 31, 2022 Response Dated September 27, 2023 File No. 001-38877 Dear Peng Zhang: We have reviewed your September 27, 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 September 14, 2023 letter. Response Dated September 27, 2023 Our Holding Company Structure and Contractual Arrangements with the VIEs, page 4 1.We note your proposed amended disclosure in response to comment 1, specifically that "[t]hese risks could ... affect our ability to accept foreign investments or list on another foreign stock exchange outside of mainland China ... ." (Emphasis added). However, please revise to clarify that recent statements by China's government (not the legal and operational risks) have or may impact your ability to accept foreign investments or list on a U.S. or other foreign exchange.
FirstName LastNamePeng Zhang Comapany NameYunji Inc. November 14, 2023 Page 2 FirstName LastName Peng Zhang Yunji Inc. November 14, 2023 Page 2 Please contact Tatanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-3336 if you have questions regarding comments on the financial statements and related matters. Please contact Cara Wirth at 202-551-7127 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Shu Du, Esq.
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United States securities and exchange commission logo
November 14, 2023
Peng Zhang
Vice President of Finance
Yunji Inc.
15/F, South Building
Hipark Phase 2, Xiaoshan District
Hangzhou, Zhejiang, 310000
People’s Republic of China
Re:Yunji Inc.
Form 20-F for Fiscal Year Ended December 31, 2022
Response Dated September 27, 2023
File No. 001-38877
Dear Peng Zhang:
We have reviewed your September 27, 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 September 14, 2023
letter.
Response Dated September 27, 2023
Our Holding Company Structure and Contractual Arrangements with the VIEs, page 4
1.We note your proposed amended disclosure in response to comment 1, specifically that
"[t]hese risks could ... affect our ability to accept foreign investments or list on another
foreign stock exchange outside of mainland China ... ." (Emphasis added). However,
please revise to clarify that recent statements by China's government (not the legal and
operational risks) have or may impact your ability to accept foreign investments or list on
a U.S. or other foreign exchange.
FirstName LastNamePeng Zhang
Comapany NameYunji Inc.
November 14, 2023 Page 2
FirstName LastName
Peng Zhang
Yunji Inc.
November 14, 2023
Page 2
Please contact Tatanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Cara Wirth at 202-551-7127 or Dietrich King at 202-551-8071 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Shu Du, Esq.