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SEC Comment Letter for Dada Nexus Ltd (CIK 0001793862) — Mar 25, 2020

Dada Nexus Ltd (CIK 0001793862)
Date: March 25, 2020 · CIK: 0001793862 · Accession: 0000000000-20-002606

AI Filing Summary & Sentiment

Date
March 25, 2020
Author
Office of Technology
Form
UPLOAD
Company
Dada Nexus Ltd (CIK 0001793862)

Letter

March 25, 2020 Philip Jiaqi Kuai Chief Executive Officer Dada Nexus Limited 22/F, Oriental Fisherman's Wharf No.1088 Yangshupu Road Yangpu District, Shanghai People's Republic of China Re:Dada Nexus Limited Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted March 13, 2020 CIK No. 0001793862 Dear Mr. Kuai: We have reviewed your amended draft registration statement and have the following comment. In our comment, 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 comment applies 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 this comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 3 to Draft Registration Statement on Form F-1 Financial Statements Subsequent Event, page F-50 1.Regarding the restricted share units and options to purchase ordinary shares granted in 2020, please disclose the per share/per unit fair value and the total amount of compensation that will be recognized in connection with these issuances. Also update the share-based compensation disclosure on page 105 related to options and unvested restricted share units to reflect these issuances.

FirstName LastNamePhilip Jiaqi Kuai Comapany NameDada Nexus Limited March 25, 2020 Page 2 FirstName LastName Philip Jiaqi Kuai Dada Nexus Limited March 25, 2020 Page 2 You may contact Joseph Cascarano, Senior Staff Accountant, at (202) 551-3376 or Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Jeff Kauten, Staff Attorney, at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Z. Julie Gao, Esq.

Show Raw Text
March 25, 2020
Philip Jiaqi Kuai
Chief Executive Officer
Dada Nexus Limited
22/F, Oriental Fisherman's Wharf
No.1088 Yangshupu Road
Yangpu District, Shanghai
People's Republic of China
Re:Dada Nexus Limited
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted March 13, 2020
CIK No. 0001793862
Dear Mr. Kuai:
            We have reviewed your amended draft registration statement and have the following
comment.  In our comment, 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 comment applies 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 this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form F-1
Financial Statements
Subsequent Event, page F-50
1.Regarding the restricted share units and options to purchase ordinary shares granted in
2020, please disclose the per share/per unit fair value and the total amount of
compensation that will be recognized in connection with these issuances.  Also update the
share-based compensation disclosure on page 105 related to options and unvested
restricted share units to reflect these issuances.

 FirstName LastNamePhilip Jiaqi Kuai
 Comapany NameDada Nexus Limited
 March 25, 2020 Page 2
 FirstName LastName
Philip Jiaqi Kuai
Dada Nexus Limited
March 25, 2020
Page 2
            You may contact Joseph Cascarano, Senior Staff Accountant, at (202) 551-3376 or
Robert Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Jeff Kauten, Staff
Attorney, at (202) 551-3447 or Larry Spirgel, Office Chief, at (202) 551-3815 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Z. Julie Gao, Esq.