SEC Comment Letter 0000000000-26-002349 to Boqii Holding Ltd (BQ)
Boqii Holding Ltd
Date: March 6, 2026 · CIK: 0001815021 · Accession: 0000000000-26-002349
AI Filing Summary & Sentiment
Reasoning
Letter
March 6, 2026 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 Form 20-F for the Fiscal Year Ended March 31, 2025 File No. 1-39547 Dear Lisa Tang: We have limited our review of your filing to the financial statements and related disclosures and have the following comment(s). Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 20-F for the Fiscal Year Ended March 31, 2025 Consolidated Financial Statements Notes to the Consolidated Financial Statements 29. Subsequent Events, page F-55 1.We note you implemented a reverse stock split in July 2025. It does not appear that your audited financial statements and related notes have been revised to reflect the split. Further, we note the announcement of fiscal 2026 first half unaudited financial results included in Form 6-K filed January 5, 2026 does not present prior-period financial information based on the new number of shares. Please tell us your consideration of retroactively adjusting all periods presented to reflect the reverse stock split in accordance with ASC 260-10-55-12 and SAB Topic 4:C. In closing, 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.
March 6, 2026 Page 2 Please contact Ta Tanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-3336 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc:Wei Wang
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March 6, 2026
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
Form 20-F for the Fiscal Year Ended March 31, 2025
File No. 1-39547
Dear Lisa Tang:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Fiscal Year Ended March 31, 2025
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
29. Subsequent Events, page F-55
1.We note you implemented a reverse stock split in July 2025. It does not appear that your
audited financial statements and related notes have been revised to reflect the split.
Further, we note the announcement of fiscal 2026 first half unaudited financial results
included in Form 6-K filed January 5, 2026 does not present prior-period financial
information based on the new number of shares. Please tell us your consideration of
retroactively adjusting all periods presented to reflect the reverse stock split in
accordance with ASC 260-10-55-12 and SAB Topic 4:C.
In closing, 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.
March 6, 2026
Page 2
Please contact Ta Tanisha Meadows at 202-551-3322 or Adam Phippen at 202-551-3336
with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Wei Wang