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SEC Comment Letter 0000000000-23-003329 to Wetouch Technology Inc. (WETH) (CIK 0001826660) (WETH)

Wetouch Technology Inc. (WETH) (CIK 0001826660)
Date: April 3, 2023 · CIK: 0001826660 · Accession: 0000000000-23-003329

AI Filing Summary & Sentiment

File numbers found in text: 333-270726

Date
April 3, 2023
Author
Office of Technology
Form
UPLOAD
Company
Wetouch Technology Inc. (WETH) (CIK 0001826660)

Letter

United States securities and exchange commission logo April 3, 2023 Zongyi Lian Chief Executive Officer Wetouch Technology Inc. No. 29, Third Main Avenue Shigao Town, Renshou County Meishan, Sichuan, 620500 China Re:Wetouch Technology Inc. Registration Statement on Form S-1 Filed March 21, 2023 File No. 333-270726 Dear Zongyi Lian: We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Registration Statement on Form S-1 Cover Page 1.Disclose whether your offering is contingent upon on final approval of your NASDAQ listing. Please ensure the disclosure is consistent with your underwriting agreement. 2.Please disclose the location of your auditor’s headquarters. 3.Please disclose whether you have written cash management policies and procedures that dictate how funds are transferred, and if so, describe these policies and procedures here and in the prospectus summary.

FirstName LastNameZongyi Lian Comapany NameWetouch Technology Inc. April 3, 2023 Page 2 FirstName LastName Zongyi Lian Wetouch Technology Inc. April 3, 2023 Page 2 Commonly Used Defined Terms, page ii 4.Please revise your definition of “China” or “PRC” to remove the exclusion of Taiwan, Hong Kong and Macau. Prospectus Summary Recent Regulatory Developments, page 8 5.We note your disclosure that you and your subsidiaries "have received all requisite permissions from Chinese authorities to operate and issue our common stock and no such permissions have been denied." Please disclose all material permissions and approvals that you are required to obtain from Chinese authorities to operate your business and to offer the securities being registered to foreign investors. General 6.We note your risk factor on page 21 that shareholders may have difficulty enforcing civil judgments from a United States court. Please include a separate section on the enforcement of civil liabilities. 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. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Aliya Ishmukhamedova, Staff Attorney, at 202-551-3447 or Jeff Kauten, Staff Attorney, at 202-551-7519 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Liang Shih

Show Raw Text
United States securities and exchange commission logo
April 3, 2023
Zongyi Lian
Chief Executive Officer
Wetouch Technology Inc.
No. 29, Third Main Avenue
Shigao Town, Renshou County
Meishan, Sichuan, 620500 China
Re:Wetouch Technology Inc.
Registration Statement on Form S-1
Filed March 21, 2023
File No. 333-270726
Dear Zongyi Lian:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form S-1
Cover Page
1.Disclose whether your offering is contingent upon on final approval of your NASDAQ
listing.  Please ensure the disclosure is consistent with your underwriting agreement.
2.Please disclose the location of your auditor’s headquarters.
3.Please disclose whether you have written cash management policies and procedures that
dictate how funds are transferred, and if so, describe these policies and procedures here
and in the prospectus summary.

 FirstName LastNameZongyi Lian
 Comapany NameWetouch Technology Inc.
 April 3, 2023 Page 2
 FirstName LastName
Zongyi Lian
Wetouch Technology Inc.
April 3, 2023
Page 2
Commonly Used Defined Terms, page ii
4.Please revise your definition of “China” or “PRC” to remove the exclusion of Taiwan,
Hong Kong and Macau.
Prospectus Summary
Recent Regulatory Developments, page 8
5.We note your disclosure that you and your subsidiaries "have received all requisite
permissions from Chinese authorities to operate and issue our common stock and no such
permissions have been denied." Please disclose all material permissions and approvals that
you are required to obtain from Chinese authorities to operate your business and to offer
the securities being registered to foreign investors.
General
6.We note your risk factor on page 21 that shareholders may have difficulty enforcing
civil judgments from a United States court. Please include a separate section on the
enforcement of civil liabilities.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Aliya Ishmukhamedova, Staff Attorney, at 202-551-3447 or Jeff Kauten,
Staff Attorney, at 202-551-7519 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Liang Shih