Correspondence 0001213900-26-031833 from Boqii Holding Ltd (BQ)
Boqii Holding Ltd
Date: March 19, 2026 · CIK: 0001815021 · Accession: 0001213900-26-031833
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Letter
Boqii Holding Ltd
Building 9, No. 388, Shengrong Road
Pudong New District, Shanghai 201210
People's Republic of China
VIA EDGAR
March 19, 2026
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
Washington, D.C. 20549
Attention: Ta Tanisha Meadows
Adam Phippen
Re: Boqii Holding Ltd Form 20-F for the Fiscal Year Ended March 31, 2025 File No. 1-39547
Ladies and Gentleman:
Boqii Holding Ltd (the " Company ") hereby transmits its response to the comment letter received from the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") on March 6, 2026 relating to the Annual Report on Form 20-F (the " Form 20-F ") for the fiscal year ended March 31, 2025 filed by the Company with the Commission on July 21, 2025.
For the Staff's convenience, we have repeated below the Staff's comment in bold and have followed the comment with the Company's response. Disclosure changes made in response to the Staff's comment have been made in Amendment No. 1 to the Form 20-F (the " Amendment ") which is being filed to the Commission contemporaneously with the submission of this letter.
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.
Response: In response to the Staff's comment, we have revised our financial statements and related notes as well as other relevant disclosures to reflect the split in the Amendment.
We thank you for your review of the foregoing and Form 20-F. If you have further comments, please feel free to contact to our counsel, Wei Wang, Esq. at wwang@egsllp.com or by telephone at (212) 370-1300.
Sincerely,
/s/
Lisa Tang
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CORRESP 1 filename1.htm Boqii Holding Ltd Building 9, No. 388, Shengrong Road Pudong New District, Shanghai 201210 People's Republic of China VIA EDGAR March 19, 2026 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Washington, D.C. 20549 Attention: Ta Tanisha Meadows Adam Phippen Re: Boqii Holding Ltd Form 20-F for the Fiscal Year Ended March 31, 2025 File No. 1-39547 Ladies and Gentleman: Boqii Holding Ltd (the " Company ") hereby transmits its response to the comment letter received from the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") on March 6, 2026 relating to the Annual Report on Form 20-F (the " Form 20-F ") for the fiscal year ended March 31, 2025 filed by the Company with the Commission on July 21, 2025. For the Staff's convenience, we have repeated below the Staff's comment in bold and have followed the comment with the Company's response. Disclosure changes made in response to the Staff's comment have been made in Amendment No. 1 to the Form 20-F (the " Amendment ") which is being filed to the Commission contemporaneously with the submission of this letter. 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. Response: In response to the Staff's comment, we have revised our financial statements and related notes as well as other relevant disclosures to reflect the split in the Amendment. We thank you for your review of the foregoing and Form 20-F. If you have further comments, please feel free to contact to our counsel, Wei Wang, Esq. at wwang@egsllp.com or by telephone at (212) 370-1300. Sincerely, /s/ Lisa Tang Name: Lisa Tang Title: Co-Chief Executive Officer and Chief Financial Officer cc: Wei Wang, Esq. Ellenoff Grossman & Schole LLP