SEC Comment Letter for TIAN RUIXIANG HOLDINGS LTD (TIRX) (CIK 0001782941) (TIRX) — Jan 9, 2020
TIAN RUIXIANG HOLDINGS LTD (TIRX) (CIK 0001782941)
Date: Jan. 9, 2020 · CIK: 0001782941 · Accession: 0000000000-20-000198
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File numbers found in text: 333-235727
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January 8, 2020
Zhe Wang
Chairman, Chief Executive Officer, and Director
TIAN RUIXIANG Holdings Ltd.
21A Jingyuan Art Center, 3 Guangqu Road
Chaoyang District, Beijing 100124
Re:TIAN RUIXIANG Holdings Ltd.
Registration Statement on Form F-1
Filed December 27, 2019
File No. 333-235727
Dear Mr. Wang:
We have reviewed your registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies 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 this comment, we may have additional comments.
Registration Statement on Form F-1 filed December 27, 2019
Index to Consolidated Financial Statements, page F-1
1.Please revise your filing to provide audited financial statements through October 31, 2019
as required by Item 8.a.4. of Form 20-F. Alternatively, if true, file as an exhibit to your
registration statement the representation identified in Instruction 2 to Item 8.A.4. of Form
20-F.
You may contact Mark Brunhofer at 202-551-3638 or Jim B. Rosenberg at 202-551-
3679 if you have questions regarding comments on the financial statements and related matters.
Please contact Irene Paik at 202-551-6553 or Mary Beth Breslin at 202-551-3625 with any other
questions.
FirstName LastNameZhe Wang
Comapany NameTIAN RUIXIANG Holdings Ltd.
January 8, 2020 Page 2
FirstName LastName
Zhe Wang
TIAN RUIXIANG Holdings Ltd.
January 8, 2020
Page 2
Sincerely,
Division of Corporation Finance
Office of Finance
cc: Ying Li