SEC Comment Letter 0000000000-23-005485 to AvePoint, Inc. (AVPT, AVPTW) (CIK 0001777921) (AVPT)
AvePoint, Inc. (AVPT, AVPTW) (CIK 0001777921)
Date: May 23, 2023 · CIK: 0001777921 · Accession: 0000000000-23-005485
AI Filing Summary & Sentiment
File numbers found in text: 001-39048
Letter
United States securities and exchange commission logo May 23, 2023 Tianyi Jiang Chief Executive Officer AvePoint, Inc. 525 Washington Blvd., Suite 1400 Jersey City, NJ 07310 Re:AvePoint, Inc. Form 10-K for the Fiscal Year ended December 31, 2022 Filed March 31, 2023 File No. 001-39048 Dear Tianyi Jiang: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-K for the Fiscal Year ended December 31, 2022 Item 9A. Controls and Procedures, page 79 1.Please revise to include Management’s annual report on internal control over financial reporting. Please ensure that your disclosure complies with Item 308(a) of Regulation S- X including disclosing the framework used by management. Refer to the Instructions to Item 308 of Regulation S-K. In closing, 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. You may contact Ryan Rohn, Senior Staff Accountant, at (202) 551-3739 or Stephen Krikorian, Accounting Branch Chief, at (202) 551-3488 with any questions. Sincerely,
FirstName LastNameTianyi Jiang Comapany NameAvePoint, Inc. May 23, 2023 Page 2 FirstName LastName Tianyi Jiang AvePoint, Inc. May 23, 2023 Page 2 Division of Corporation Finance Office of Technology
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United States securities and exchange commission logo
May 23, 2023
Tianyi Jiang
Chief Executive Officer
AvePoint, Inc.
525 Washington Blvd., Suite 1400
Jersey City, NJ 07310
Re:AvePoint, Inc.
Form 10-K for the Fiscal Year ended December 31, 2022
Filed March 31, 2023
File No. 001-39048
Dear Tianyi Jiang:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. Please respond to this comment 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 comment applies to your facts and circumstances, please
tell us why in your response. After reviewing your response to this comment, we may have
additional comments.
Form 10-K for the Fiscal Year ended December 31, 2022
Item 9A. Controls and Procedures, page 79
1.Please revise to include Management’s annual report on internal control over financial
reporting. Please ensure that your disclosure complies with Item 308(a) of Regulation S-
X including disclosing the framework used by management. Refer to the Instructions to
Item 308 of Regulation S-K.
In closing, 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.
You may contact Ryan Rohn, Senior Staff Accountant, at (202) 551-3739 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 with any questions.
Sincerely,
FirstName LastNameTianyi Jiang
Comapany NameAvePoint, Inc.
May 23, 2023 Page 2
FirstName LastName
Tianyi Jiang
AvePoint, Inc.
May 23, 2023
Page 2
Division of Corporation Finance
Office of Technology