SEC Comment Letter 0000000000-23-013712 to Tuya Inc. (TUYA) (CIK 0001829118) (TUYA)
Tuya Inc. (TUYA) (CIK 0001829118)
Date: Dec. 15, 2023 · CIK: 0001829118 · Accession: 0000000000-23-013712
AI Filing Summary & Sentiment
File numbers found in text: 001-40210
Letter
United States securities and exchange commission logo December 15, 2023 Yao (Jessie) Liu Chief Financial Officer Tuya Inc. 10/F, Building A, Huace Center Xihu District, Hangzhou City Zhejiang, 310012 People's Republic of China Re:Tuya Inc. Form 20-F for the Fiscal Year Ended December 31, 2022 Response dated November 22, 2023 File No. 001-40210 Dear Yao (Jessie) Liu: We have reviewed your November 22, 2023 response to our comment letter and have the following comment. 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. Unless we note otherwise, any references to prior comments are to comments in our October 16, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 General 1.We appreciate the offer in your response to prior comment 3 to provide a written analysis from your U.S. counsel explaining to us, on behalf of the company, counsel’s opinion regarding section 3(b)(1) of the Investment Company Act of 1940 regarding certain of the company’s subsidiaries. The Staff believes that such analysis would be useful and, accordingly, requests that the company ask its U.S. counsel to provide such analysis. We may have additional comments following receipt of the 3(b)(1) analysis.
FirstName LastNameYao (Jessie) Liu Comapany NameTuya Inc. December 15, 2023 Page 2 FirstName LastName Yao (Jessie) Liu Tuya Inc. December 15, 2023 Page 2 Please contact Melissa Kindelan at (202) 551-3564 or Christine Dietz at (202) 551-3408 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Xiaolang Chai, Capital Market Director
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United States securities and exchange commission logo
December 15, 2023
Yao (Jessie) Liu
Chief Financial Officer
Tuya Inc.
10/F, Building A, Huace Center
Xihu District, Hangzhou City
Zhejiang, 310012
People's Republic of China
Re:Tuya Inc.
Form 20-F for the Fiscal Year Ended December 31, 2022
Response dated November 22, 2023
File No. 001-40210
Dear Yao (Jessie) Liu:
We have reviewed your November 22, 2023 response to our comment letter and have the
following comment.
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. Unless
we note otherwise, any references to prior comments are to comments in our October 16,
2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.We appreciate the offer in your response to prior comment 3 to provide a written analysis
from your U.S. counsel explaining to us, on behalf of the company, counsel’s opinion
regarding section 3(b)(1) of the Investment Company Act of 1940 regarding certain of the
company’s subsidiaries. The Staff believes that such analysis would be useful and,
accordingly, requests that the company ask its U.S. counsel to provide such analysis. We
may have additional comments following receipt of the 3(b)(1) analysis.
FirstName LastNameYao (Jessie) Liu
Comapany NameTuya Inc.
December 15, 2023 Page 2
FirstName LastName
Yao (Jessie) Liu
Tuya Inc.
December 15, 2023
Page 2
Please contact Melissa Kindelan at (202) 551-3564 or Christine Dietz at (202) 551-3408
if you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Xiaolang Chai, Capital Market Director