SEC Comment Letter for Pony Group Inc. (PNYG) (CIK 0001784058) (PNYG) — Apr 30, 2020
Pony Group Inc. (PNYG) (CIK 0001784058)
Date: April 30, 2020 · CIK: 0001784058 · Accession: 0000000000-20-003712
AI Filing Summary & Sentiment
File numbers found in text: 333-234358
Letter
United States securities and exchange commission logo April 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. 4 to Registration Statement on Form S-1 Filed April 23, 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 30, 2020 letter. Amendment No. 4 to Registration Statement on Form S-1 filed April 23, 2020 Dilution, page 27 1.We note your computations of net tangible book value prior to and after the offering include intangible assets. Please revise your disclosures to exclude these amounts from your computations accordingly. General 2.We note your response to our prior comment 1. Please address more specifically how COVID-19 has impacted your services, explaining the extents to which you have
FirstName LastNameWenxian Fan Comapany NamePony Group Inc. April 30, 2020 Page 2 FirstName LastName Wenxian Fan Pony Group Inc. April 30, 2020 Page 2 reopened your business and demand has returned for your business following your office closure that ended on February 10, 2020. Also expand your disclosure to explain any current travel restrictions between Guangdong Province and Hong Kong. In addition discuss your office shutdown between January 19, 2020 and February 10, 2020 in your Prospectus Summary, for example in a Recent Developments section. Refer to CF Disclosure Guidance: Topic No. 9 for further guidance, available at https://www.sec.gov/corpfin/coronavirus-covid-19.
As a related matter, please further describe, and quantify to the extent possible, any known trends and uncertainties that have had, or that you reasonably expect will have, a material favorable or unfavorable impact on revenue or results of operations, in light of the impact of COVID-19 in your business. 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 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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United States securities and exchange commission logo
April 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. 4 to Registration Statement on Form S-1
Filed April 23, 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 30, 2020 letter.
Amendment No. 4 to Registration Statement on Form S-1 filed April 23, 2020
Dilution, page 27
1.We note your computations of net tangible book value prior to and after the offering
include intangible assets. Please revise your disclosures to exclude these amounts from
your computations accordingly.
General
2.We note your response to our prior comment 1. Please address more specifically how
COVID-19 has impacted your services, explaining the extents to which you have
FirstName LastNameWenxian Fan
Comapany NamePony Group Inc.
April 30, 2020 Page 2
FirstName LastName
Wenxian Fan
Pony Group Inc.
April 30, 2020
Page 2
reopened your business and demand has returned for your business following your office
closure that ended on February 10, 2020. Also expand your disclosure to explain any
current travel restrictions between Guangdong Province and Hong Kong. In addition
discuss your office shutdown between January 19, 2020 and February 10, 2020 in your
Prospectus Summary, for example in a Recent Developments section. Refer to CF
Disclosure Guidance: Topic No. 9 for further guidance, available at
https://www.sec.gov/corpfin/coronavirus-covid-19.
As a related matter, please further describe, and quantify to the extent possible, any known
trends and uncertainties that have had, or that you reasonably expect will have, a material
favorable or unfavorable impact on revenue or results of operations, in light of the impact
of COVID-19 in your business.
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
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