SEC Comment Letter 0000000000-23-010500 to ATRenew Inc. (RERE) (CIK 0001838957) (RERE)
ATRenew Inc. (RERE) (CIK 0001838957)
Date: Sept. 22, 2023 · CIK: 0001838957 · Accession: 0000000000-23-010500
AI Filing Summary & Sentiment
File numbers found in text: 001-40486
Referenced dates: August 21, 2023
Letter
United States securities and exchange commission logo September 22, 2023 Chen Chen Chief Financial Officer ATRenew Inc. 12th Floor, No. 6 Building, 433 Songhu Road, Shanghai People’s Republic of China Re:ATRenew Inc. Annual Report on Form 20-F Filed April 18, 2023 Response Dated August 21, 2023 File No. 001-40486 Dear Chen Chen: We have reviewed your August 21, 2023 response to our comment letter and have the following 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 24, 2023 letter. Response Letter dated August 21, 2023 Transfer of Funds and Other Assets Within Our Organization, page 6 1.We note your response to comment 9, as well as your proposed disclosure. Where you refer to the "Company's subsidiaries" throughout your response, revise to identify which particular subsidiaries. Tell us what your disclosure will look like. Summary of Risk Factors Risks Related to Doing Business in China, page 11 2.We note your response to comment 13, as well as your proposed disclosure that the PRC government "may intervene or exert more oversight and control over offerings conducted overseas." We reissue the comment in-part. In future filings, revise to disclose the risks
FirstName LastNameChen Chen Comapany NameATRenew Inc. September 22, 2023 Page 2 FirstName LastName Chen Chen ATRenew Inc. September 22, 2023 Page 2 that the PRC government may intervene or influence your operations at any time, which could result in a material change in your operations and/or the value of your ADSs. In this regard, your proposed disclosure appears limited to the risks associated with intervention as well as more oversight and control over foreign offerings. Tell us what your disclosure will look like. 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 Brian Fetterolf at 202-551-6613 or Donald Field at 202-551-3680 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Shu Du
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United States securities and exchange commission logo
September 22, 2023
Chen Chen
Chief Financial Officer
ATRenew Inc.
12th Floor, No. 6 Building, 433 Songhu Road, Shanghai
People’s Republic of China
Re:ATRenew Inc.
Annual Report on Form 20-F
Filed April 18, 2023
Response Dated August 21, 2023
File No. 001-40486
Dear Chen Chen:
We have reviewed your August 21, 2023 response to our comment letter and have the
following 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to comments in our
July 24, 2023 letter.
Response Letter dated August 21, 2023
Transfer of Funds and Other Assets Within Our Organization, page 6
1.We note your response to comment 9, as well as your proposed disclosure. Where you
refer to the "Company's subsidiaries" throughout your response, revise to identify which
particular subsidiaries. Tell us what your disclosure will look like.
Summary of Risk Factors
Risks Related to Doing Business in China, page 11
2.We note your response to comment 13, as well as your proposed disclosure that the PRC
government "may intervene or exert more oversight and control over offerings conducted
overseas." We reissue the comment in-part. In future filings, revise to disclose the risks
FirstName LastNameChen Chen
Comapany NameATRenew Inc.
September 22, 2023 Page 2
FirstName LastName
Chen Chen
ATRenew Inc.
September 22, 2023
Page 2
that the PRC government may intervene or influence your operations at any time, which
could result in a material change in your operations and/or the value of your ADSs. In
this regard, your proposed disclosure appears limited to the risks associated with
intervention as well as more oversight and control over foreign offerings. Tell us what
your disclosure will look like.
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 Brian Fetterolf at 202-551-6613 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Shu Du