SEC Comment Letter for Li Auto Inc. (LI, LAAOF) (CIK 0001791706) (LI) — Mar 27, 2020
Li Auto Inc. (LI, LAAOF) (CIK 0001791706)
Date: March 27, 2020 · CIK: 0001791706 · Accession: 0000000000-20-002688
AI Filing Summary & Sentiment
Referenced dates: January 31, 2020
Letter
March 27, 2020 Tie Li Director and Chief Financial Officer Leading Ideal Inc. 8th Floor, Block D, Building 8, 4th District of Wangjing East Garden, Chaoyang District, Beijing 100102 People's Republic of China Re:Leading Ideal Inc. Amendment No. 2 to Draft Registration Statement on Form F-1 Filed March 13, 2020 CIK No. 0001791706 Dear Mr. Li: We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. 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 the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Draft Registration Statement on Form F-1 Filed on March 13, 2020 21. Convertible Redeemable Preferred Shares and Warrants Accounting for Preferred Shares, page F-52 1.We note your response to comment one in our letter dated January 31, 2020. Please also remove the references to the "independent valuation firm" and "independent valuation advice" from pages 95, 96 and F-31. You may contact Ernest Greene, Staff Accountant at (202) 551-3733 or Kevin Stertzel, Staff Accountant at (202) 551-3723 if you have questions regarding comments on the financial
FirstName LastNameTie Li Comapany NameLeading Ideal Inc. March 27, 2020 Page 2 FirstName LastName Tie Li Leading Ideal Inc. March 27, 2020 Page 2 statements and related matters. Please contact Sherry Haywood, Staff Attorney at (202) 551- 3345 or Asia Timmons-Pierce, Staff Attorney at (202) 551-3754 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Z. Julie Gao
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March 27, 2020
Tie Li
Director and Chief Financial Officer
Leading Ideal Inc.
8th Floor, Block D, Building 8,
4th District of Wangjing East Garden,
Chaoyang District, Beijing 100102
People's Republic of China
Re:Leading Ideal Inc.
Amendment No. 2 to Draft Registration Statement on Form F-1
Filed March 13, 2020
CIK No. 0001791706
Dear Mr. Li:
We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 Filed on March 13, 2020
21. Convertible Redeemable Preferred Shares and Warrants
Accounting for Preferred Shares, page F-52
1.We note your response to comment one in our letter dated January 31, 2020. Please also
remove the references to the "independent valuation firm" and "independent valuation
advice" from pages 95, 96 and F-31.
You may contact Ernest Greene, Staff Accountant at (202) 551-3733 or Kevin Stertzel,
Staff Accountant at (202) 551-3723 if you have questions regarding comments on the financial
FirstName LastNameTie Li
Comapany NameLeading Ideal Inc.
March 27, 2020 Page 2
FirstName LastName
Tie Li
Leading Ideal Inc.
March 27, 2020
Page 2
statements and related matters. Please contact Sherry Haywood, Staff Attorney at (202) 551-
3345 or Asia Timmons-Pierce, Staff Attorney at (202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Z. Julie Gao