SEC Comment Letter 0000000000-23-001483 to Boqii Holding Ltd (BQ)
Boqii Holding Ltd
Date: Feb. 13, 2023 · CIK: 0001815021 · Accession: 0000000000-23-001483
AI Filing Summary & Sentiment
Reasoning
Letter
United States securities and exchange commission logo February 13, 2023 Lisa Tang Co-Chief Executive Officer Boqii Holding Ltd Building 9, No. 388, Shengrong Road, Pudong New District, Shanghai 201210 The People’s Republic of China Re:Boqii Holding Ltd Form 20-F for the Fiscal Year Ended March 31, 2022 Filed July 27, 2022 File No. 1-39547 Dear Lisa Tang: We have reviewed your filing 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 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. Form 20-F for the Fiscal Year Ended March 31, 2022 Item 19. Exhibits Exhibits 12.1 and 12.2, page 145 1.Please include paragraph 4(b) and the introductory language in paragraph 4 referring to internal control over financial reporting as the transition period that allows these omissions is over. Refer to Exchange Act Rule 13a-14(a) and Item 601(b)(31) of Regulation S-K. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameLisa Tang Comapany NameBoqii Holding Ltd February 13, 2023 Page 2 FirstName LastName Lisa Tang Boqii Holding Ltd February 13, 2023 Page 2
You may contact Tony Watson at (202) 551-3318 or Adam Phippen at (202) 551-3336 if you have questions regarding comments. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
February 13, 2023
Lisa Tang
Co-Chief Executive Officer
Boqii Holding Ltd
Building 9, No. 388, Shengrong Road, Pudong
New District, Shanghai 201210
The People’s Republic of China
Re:Boqii Holding Ltd
Form 20-F for the Fiscal Year Ended March 31, 2022
Filed July 27, 2022
File No. 1-39547
Dear Lisa Tang:
We have reviewed your filing 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 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.
Form 20-F for the Fiscal Year Ended March 31, 2022
Item 19. Exhibits
Exhibits 12.1 and 12.2, page 145
1.Please include paragraph 4(b) and the introductory language in paragraph 4 referring to
internal control over financial reporting as the transition period that allows these
omissions is over. Refer to Exchange Act Rule 13a-14(a) and Item 601(b)(31) of
Regulation S-K.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameLisa Tang
Comapany NameBoqii Holding Ltd
February 13, 2023 Page 2
FirstName LastName
Lisa Tang
Boqii Holding Ltd
February 13, 2023
Page 2
You may contact Tony Watson at (202) 551-3318 or Adam Phippen at (202) 551-3336 if
you have questions regarding comments.
Sincerely,
Division of Corporation Finance
Office of Trade & Services