SEC Comment Letter for Pony Group Inc. (PNYG) (CIK 0001784058) (PNYG) — Mar 30, 2020
Pony Group Inc. (PNYG) (CIK 0001784058)
Date: March 30, 2020 · CIK: 0001784058 · Accession: 0000000000-20-002734
AI Filing Summary & Sentiment
File numbers found in text: 333-234358
Letter
March 30, 2020 Wenxian Fan Chief Executive Officer Pony Group Inc. Engineer Experiment Building, A202 7 Gaoxin South Avenue, Nanshan District, Shenzhen, Guangdong Province, People’s Republic of China Re:Pony Group Inc. Amendment No. 3 to Registration Statement on Form S-1 Filed March 24, 2020 File No. 333-234358 Dear Ms. Fan: 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. Unless we note otherwise, our references to prior comments are to comments in our March 13, 2020 letter. Amended Form S-1 Filed March 24, 2020 General 1.Please revise your prospectus disclosure to address any material impacts that the coronavirus disease 2019 (COVID-19) has had or may have on your business. We note for example travel restrictions and social distancing requirements in the markets in which you operate. Please refer to CF Disclosure Guidance: Topic No. 9 for further guidance, available at https://www.sec.gov/corpfin/coronavirus-covid-19. You may contact Melissa Gilmore at 202-551-3777 or Melissa Raminpour at 202-551- 3379 if you have questions regarding comments on the financial statements and related
FirstName LastNameWenxian Fan Comapany NamePony Group Inc. March 30, 2020 Page 2 FirstName LastName Wenxian Fan Pony Group Inc. March 30, 2020 Page 2 matters. Please contact Susan Block at 202-551-3210 or John Dana Brown at 202-551-3859 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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March 30, 2020
Wenxian Fan
Chief Executive Officer
Pony Group Inc.
Engineer Experiment Building, A202
7 Gaoxin South Avenue, Nanshan District,
Shenzhen, Guangdong Province,
People’s Republic of China
Re:Pony Group Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed March 24, 2020
File No. 333-234358
Dear Ms. Fan:
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. Unless we note
otherwise, our references to prior comments are to comments in our March 13, 2020 letter.
Amended Form S-1 Filed March 24, 2020
General
1.Please revise your prospectus disclosure to address any material impacts that the
coronavirus disease 2019 (COVID-19) has had or may have on your business. We note
for example travel restrictions and social distancing requirements in the markets in which
you operate. Please refer to CF Disclosure Guidance: Topic No. 9 for further guidance,
available at https://www.sec.gov/corpfin/coronavirus-covid-19.
You may contact Melissa Gilmore at 202-551-3777 or Melissa Raminpour at 202-551-
3379 if you have questions regarding comments on the financial statements and related
FirstName LastNameWenxian Fan
Comapany NamePony Group Inc.
March 30, 2020 Page 2
FirstName LastName
Wenxian Fan
Pony Group Inc.
March 30, 2020
Page 2
matters. Please contact Susan Block at 202-551-3210 or John Dana Brown at 202-551-3859
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance