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UPLOAD Filing

Boqii Holding Ltd
Date: May 27, 2025 · CIK: 0001815021 · Accession: 0000000000-25-005570

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File numbers found in text: 333-286239

Date
May 27, 2025
Author
Division of
Form
UPLOAD
Company
Boqii Holding Ltd

Letter

Re: Boqii Holding Ltd Amendment No. 1 to Registration Statement on Form F-1 Filed May 9, 2025 File No. 333-286239 Dear Yingzhi (Lisa) Tang:

May 27, 2025

Yingzhi (Lisa) Tang Co-Chief Executive Officer and Chief Financial Officer Boqii Holding Ltd Building 9, No. 388, Shengrong Road, Pudong New District, Shanghai 201210, People s Republic of China

We have reviewed your amended registration statement and have the following comment(s).

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our April 25, 2025 letter.

Amendment No. 1 to Registration Statement on Form F-1 Filed May 9, 2025 Prospectus Summary, page 19

1. We note your amended disclosure in response to prior comment 7. Please revise to disclose each permission or approval that you, your subsidiaries, or the VIEs are required to obtain from Chinese authorities to operate your business. May 27, 2025 Page 2

Please contact Cara Wirth at 202-551-7127 or Dietrich King at 202-551-8071 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Ben Smolij

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 27, 2025

Yingzhi (Lisa) Tang
Co-Chief Executive Officer and Chief Financial Officer
Boqii Holding Ltd
Building 9, No. 388, Shengrong Road, Pudong
New District, Shanghai 201210, People s Republic of China

 Re: Boqii Holding Ltd
 Amendment No. 1 to Registration Statement on Form F-1
 Filed May 9, 2025
 File No. 333-286239
Dear Yingzhi (Lisa) Tang:

 We have reviewed your amended registration statement and have the
following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our April 25,
2025 letter.

Amendment No. 1 to Registration Statement on Form F-1 Filed May 9, 2025
Prospectus Summary, page 19

1. We note your amended disclosure in response to prior comment 7. Please
revise to
 disclose each permission or approval that you, your subsidiaries, or the
VIEs are
 required to obtain from Chinese authorities to operate your business.
 May 27, 2025
Page 2

 Please contact Cara Wirth at 202-551-7127 or Dietrich King at
202-551-8071 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Ben Smolij
</TEXT>
</DOCUMENT>