SEC Comment Letter 0000000000-23-002220 to Smart Share Global Ltd (EM) (CIK 0001834253) (EM)
Smart Share Global Ltd (EM) (CIK 0001834253)
Date: March 6, 2023 · CIK: 0001834253 · Accession: 0000000000-23-002220
AI Filing Summary & Sentiment
File numbers found in text: 001-40298
Letter
United States securities and exchange commission logo March 6, 2023 Mars Guangyuan Cai Chief Executive Officer Smart Share Global Ltd 6th Floor, 799 Tianshan W Road Changning District, Shanghai 200335 People's Republic of China Re:Smart Share Global Ltd Form 20-F for the Fiscal Year Ended December 31, 2021 Correspondence Filed February 13, 2023 File No. 001-40298 Dear Mars Guangyuan Cai: We have reviewed your February 13, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our February 1, 2023 letter. Correspondence filed February 13, 2023 Introduction, page 1 1.We note your response to comment 1 and reissue in part. In future filings, please revise your definition of "China" and "PRC" to state that the legal and operation risks associated with operating in China also apply to operations in Hong Kong, as PRC regulations that may not be currently applicable to Hong Kong companies may become applicable given the PRC's oversight of that region.
FirstName LastNameMars Guangyuan Cai Comapany NameSmart Share Global Ltd March 6, 2023 Page 2 FirstName LastName Mars Guangyuan Cai Smart Share Global Ltd March 6, 2023 Page 2 You may contact Tony Watson at 202-551-3318 or Adam Phippen at 202-551-3336 if you have questions regarding comments on the financial statements and related matters. Please contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Haiping Li
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United States securities and exchange commission logo
March 6, 2023
Mars Guangyuan Cai
Chief Executive Officer
Smart Share Global Ltd
6th Floor, 799 Tianshan W Road
Changning District, Shanghai 200335
People's Republic of China
Re:Smart Share Global Ltd
Form 20-F for the Fiscal Year Ended December 31, 2021
Correspondence Filed February 13, 2023
File No. 001-40298
Dear Mars Guangyuan Cai:
We have reviewed your February 13, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
February 1, 2023 letter.
Correspondence filed February 13, 2023
Introduction, page 1
1.We note your response to comment 1 and reissue in part. In future filings, please revise
your definition of "China" and "PRC" to state that the legal and operation risks associated
with operating in China also apply to operations in Hong Kong, as PRC regulations that
may not be currently applicable to Hong Kong companies may become applicable given
the PRC's oversight of that region.
FirstName LastNameMars Guangyuan Cai
Comapany NameSmart Share Global Ltd
March 6, 2023 Page 2
FirstName LastName
Mars Guangyuan Cai
Smart Share Global Ltd
March 6, 2023
Page 2
You may contact Tony Watson at 202-551-3318 or Adam Phippen at 202-551-3336 if
you have questions regarding comments on the financial statements and related matters. Please
contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Haiping Li