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SEC Comment Letter 0000000000-23-005961 to Planet Image International Ltd (YIBO)

Planet Image International Ltd
Date: June 5, 2023 · CIK: 0001868395 · Accession: 0000000000-23-005961

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File numbers found in text: 333-263602

Date
June 5, 2023
Author
Shaofang Weng
Form
UPLOAD
Company
Planet Image International Ltd

Letter

United States securities and exchange commission logo June 5, 2023 Shaofang Weng Chief Executive Officer Planet Image International Ltd No. 756 Guangfu Road Hi-tech Development Zone Xinyu City, Jiangxi Province People’s Republic of China Re:Planet Image International Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed May 23, 2023 File No. 333-263602 Dear Shaofang Weng: We have reviewed your amended registration statement 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 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. Unless we note otherwise, our references to prior comments are to comments in our May 12, 2023 letter. Amendment No. 2 to Registration Statement on Form F-1 Prospectus Summary Cash Transfer and Dividend Distributions, page 8 1.We note your revised disclosure in response to prior comment 2, which summarizes the cash flows that have occurred between your Mainland PRC subsidiaries and your other subsidiaries to date. Please revise your table to identify the "other subsidiaries" where cash has flowed to and from your Mainland PRC subsidiaries. Note that only information relating to the periods for which you have provided financial statements needs to be included.

FirstName LastNameShaofang Weng Comapany NamePlanet Image International Ltd June 5, 2023 Page 2 FirstName LastName Shaofang Weng Planet Image International Ltd June 5, 2023 Page 2 You may contact Joanna Lam, Staff Accountant, at 202-551-3476 or Raj Rajan, Staff Accountant, at 202-551-3388 if you have questions regarding comments on the financial statements and related matters. Please contact Irene Barberena-Meissner, Staff Attorney, at 202- 551-6548 or Karina Dorin, Staff Attorney, at 202-551-3763 with any other questions Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Cindy Li, Esq.

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United States securities and exchange commission logo
June 5, 2023
Shaofang Weng
Chief Executive Officer
Planet Image International Ltd
No. 756 Guangfu Road
Hi-tech Development Zone
Xinyu City, Jiangxi Province
People’s Republic of China
Re:Planet Image International Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed May 23, 2023
File No. 333-263602
Dear Shaofang Weng:
            We have reviewed your amended registration statement 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 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.  Unless we note
otherwise, our references to prior comments are to comments in our May 12, 2023 letter.
Amendment No. 2 to Registration Statement on Form F-1
Prospectus Summary
Cash Transfer and Dividend Distributions, page 8
1.We note your revised disclosure in response to prior comment 2, which summarizes the
cash flows that have occurred between your Mainland PRC subsidiaries and your other
subsidiaries to date.  Please revise your table to identify the "other subsidiaries" where
cash has flowed to and from your Mainland PRC subsidiaries.  Note that only information
relating to the periods for which you have provided financial statements needs to be
included.

 FirstName LastNameShaofang  Weng
 Comapany NamePlanet Image International Ltd
 June 5, 2023 Page 2
 FirstName LastName
Shaofang  Weng
Planet Image International Ltd
June 5, 2023
Page 2
            You may contact Joanna Lam, Staff Accountant, at 202-551-3476 or Raj Rajan, Staff
Accountant, at 202-551-3388 if you have questions regarding comments on the financial
statements and related matters.  Please contact Irene Barberena-Meissner, Staff Attorney, at 202-
551-6548 or Karina Dorin, Staff Attorney, at 202-551-3763 with any other questions
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Cindy Li, Esq.