SEC Comment Letter for TIAN RUIXIANG HOLDINGS LTD (TIRX) (CIK 0001782941) (TIRX) — May 22, 2020
TIAN RUIXIANG HOLDINGS LTD (TIRX) (CIK 0001782941)
Date: May 22, 2020 · CIK: 0001782941 · Accession: 0000000000-20-004614
AI Filing Summary & Sentiment
File numbers found in text: 333-235727
Letter
United States securities and exchange commission logo May 22, 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. Amendment No. 2 to Registration Statement on Form F-1 Filed April 27, 2020 File No. 333-235727 Dear Mr. Wang: We have reviewed your amended registration statement 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. Amendment No. 2 to Registration Statement on Form F-1 filed April 27, 2020 Because we are a Cayman Island company and all of our business is conducted in the PRC..., page 21 1.Here or under “Enforcement of Civil Liabilities,” please include disclosure related to any new restrictions on the ability to bring actions under Article 177 of the new amendments to the Chinese securities laws that took effect on March 1, 2020. Exhibits 2.Please file your agreements with Picc Beijing Branch and China United Life Insurance Co., Ltd. Beijing Branch as exhibits to the registration statement, or tell us why you do not believe this is required. See Item 601(b)(10) of Regulation S-K.
FirstName LastNameZhe Wang Comapany NameTIAN RUIXIANG Holdings Ltd. May 22, 2020 Page 2 FirstName LastName Zhe Wang TIAN RUIXIANG Holdings Ltd. May 22, 2020 Page 2 You may contact Ben Phippen at 202-551-3697 or Amit Pande at 202-551-3423 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. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Ying Li, Esq.
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United States securities and exchange commission logo
May 22, 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.
Amendment No. 2 to Registration Statement on Form F-1
Filed April 27, 2020
File No. 333-235727
Dear Mr. Wang:
We have reviewed your amended registration statement 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.
Amendment No. 2 to Registration Statement on Form F-1 filed April 27, 2020
Because we are a Cayman Island company and all of our business is conducted in the PRC...,
page 21
1.Here or under “Enforcement of Civil Liabilities,” please include disclosure related to any
new restrictions on the ability to bring actions under Article 177 of the new amendments
to the Chinese securities laws that took effect on March 1, 2020.
Exhibits
2.Please file your agreements with Picc Beijing Branch and China United Life Insurance
Co., Ltd. Beijing Branch as exhibits to the registration statement, or tell us why you do not
believe this is required. See Item 601(b)(10) of Regulation S-K.
FirstName LastNameZhe Wang
Comapany NameTIAN RUIXIANG Holdings Ltd.
May 22, 2020 Page 2
FirstName LastName
Zhe Wang
TIAN RUIXIANG Holdings Ltd.
May 22, 2020
Page 2
You may contact Ben Phippen at 202-551-3697 or Amit Pande at 202-551-3423 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.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc: Ying Li, Esq.