SEC Comment Letter 0000000000-23-003025 to Pony Group Inc. (PNYG) (CIK 0001784058) (PNYG)
Pony Group Inc. (PNYG) (CIK 0001784058)
Date: March 27, 2023 · CIK: 0001784058 · Accession: 0000000000-23-003025
AI Filing Summary & Sentiment
File numbers found in text: 333-234358
Letter
United States securities and exchange commission logo March 27, 2023 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. 2 to Form 10-K for Fiscal Year Ended December 31, 2021 Filed February 3, 2022 File No. 333-234358 Dear Wenxian Fan: We have reviewed your February 2, 2023 response to our comment letter 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. Our reference to the prior comment is to the comment in our January 19, 2023 letter. Amendment No. 2 to Form 10-K for Fiscal Year Ended December 31, 2021 Regulatory Permissions and Developments, page 3 1.We note your response to comment 3, including your conclusions on pages 3, 24 and 29 that neither you nor your subsidiaries are required to obtain any permissions or approvals from the PRC and Hong Kong governments. Please further revise your disclosure to state whether you relied on an opinion of counsel in coming to these conclusions and, if so, name counsel. If you did not rely on an opinion of counsel with respect to your conclusions that you and your subsidiaries are not required to obtain any permissions or approvals to operate your business or offer securities, state that that is the case and explain why such an opinion was not obtained; further, discuss how you came to such conclusions, why that is the case, and the basis on which you made such determinations.
FirstName LastNameWenxian Fan Comapany NamePony Group Inc. March 27, 2023 Page 2 FirstName LastName Wenxian Fan Pony Group Inc. March 27, 2023 Page 2
Please contact Rucha Pandit at (202) 551-6022 or Lilyanna Peyser at (202) 511- 3222 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Richard I. Anslow
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United States securities and exchange commission logo
March 27, 2023
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. 2 to Form 10-K for Fiscal Year Ended December 31, 2021
Filed February 3, 2022
File No. 333-234358
Dear Wenxian Fan:
We have reviewed your February 2, 2023 response to our comment letter 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. Our
reference to the prior comment is to the comment in our January 19, 2023 letter.
Amendment No. 2 to Form 10-K for Fiscal Year Ended December 31, 2021
Regulatory Permissions and Developments, page 3
1.We note your response to comment 3, including your conclusions on pages 3, 24 and 29
that neither you nor your subsidiaries are required to obtain any permissions or
approvals from the PRC and Hong Kong governments. Please further revise your
disclosure to state whether you relied on an opinion of counsel in coming to these
conclusions and, if so, name counsel. If you did not rely on an opinion of counsel with
respect to your conclusions that you and your subsidiaries are not required to obtain any
permissions or approvals to operate your business or offer securities, state that that is the
case and explain why such an opinion was not obtained; further, discuss how you came to
such conclusions, why that is the case, and the basis on which you made such
determinations.
FirstName LastNameWenxian Fan
Comapany NamePony Group Inc.
March 27, 2023 Page 2
FirstName LastName
Wenxian Fan
Pony Group Inc.
March 27, 2023
Page 2
Please contact Rucha Pandit at (202) 551-6022 or Lilyanna Peyser at (202) 511-
3222 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Richard I. Anslow