SecProbe.io

Filing text and metadata
Intelligence Terminal Search Topics Monthly Activity About

Correspondence 0001013762-23-004330 from Planet Image International Ltd (YIBO)

Planet Image International Ltd
Date: Oct. 17, 2023 · CIK: 0001868395 · Accession: 0001013762-23-004330

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 333-263602

Date
October 17, 2023
Author
/s/ Shaofang Weng
Form
CORRESP
Company
Planet Image International Ltd

Letter

VIA EDGAR Division of Corporation Finance Office of Energy & Transportation Planet Image International Limited Amendment No. 5 to Registration Statement on Form F-1 Filed September 28, 2023 File No. 333-263602

Dear Ms. Barberena-Meissner and Ms. Dorin:

Planet Image International Limited (the “Company”, “we”, “us” or “our”) hereby transmits its response to the letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated October 12, 2023 regarding its Amendment No. 5 to Registration Statement on Form F-1 (the “Amendment No. 5 to Registration Statement”) filed on September 28, 2023. For ease of reference, we have repeated the Commission’s comment in this response letter. An Amendment No. 6 to the Registration Statement on Form F-1 (“Amendment No. 6 to the Registration Statement”) is being filed to accompany this response letter.

Amendment No. 5 to Registration Statement on Form F-1

General

1. Your revised disclosure in response to prior comment 1 does not fully address the issues raised therein and we reissue the comment. We note the changes you made to your disclosure appearing on the cover page, Prospectus Summary and Risk Factor sections relating to legal and operational risks associated with operating in China and PRC regulations. It is unclear to us that there have been changes in the regulatory environment in the PRC since the amendment that was filed on June 7, 2023, warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence your operations at any time, or may exert control over operations of your business, which could result in a material change in your operations and/or the value of the securities you are registering for sale. We remind you that, pursuant to federal securities rules, the term “control” (including the terms “controlling,” “controlled by,” and “under common control with”) as defined in Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or cause the direction of the management and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China can change quickly with little advance notice. We do not believe that your revised disclosure conveys the same risk. Please restore your disclosures in these areas to the disclosures as they existed in the registration statement as of June 7, 2023.

Response: In response to the Staff’s comment, we revised our disclosure throughout Amendment No. 5 to the Registration Statement to restore our disclosures in the above-mentioned areas.

We thank the Staff for its review of the foregoing. If you have further comments, we ask that you forward them by electronic mail to our counsel, Ying Li at yli@htflawyers.com or by telephone at 212-530-2206.

Very truly yours,
/s/ Shaofang Weng

Show Raw Text
CORRESP
1
filename1.htm

Planet Image International Limited

October 17, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, N.E.

Washington, DC 20549

Attn: Irene Barberena-Meissner and Karina Dorin

    Re:

    Planet Image International Limited

    Amendment No. 5 to Registration Statement on Form F-1

    Filed September 28, 2023

    File No. 333-263602

Dear Ms. Barberena-Meissner and Ms. Dorin:

Planet Image International
Limited (the “Company”, “we”, “us” or “our”) hereby transmits
its response to the letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”), dated October 12, 2023 regarding its Amendment No. 5 to Registration Statement on Form F-1 (the “Amendment
No. 5 to Registration Statement”) filed on September 28, 2023. For ease of reference, we have repeated the Commission’s
comment in this response letter. An Amendment No. 6 to the Registration Statement on Form F-1 (“Amendment No. 6 to the Registration
Statement”) is being filed to accompany this response letter.

Amendment No. 5 to Registration Statement on
Form F-1

General

1. Your revised disclosure in response to prior
comment 1 does not fully address the issues raised therein and we reissue the comment. We note the changes you made to your disclosure
appearing on the cover page, Prospectus Summary and Risk Factor sections relating to legal and operational risks associated with operating
in China and PRC regulations. It is unclear to us that there have been changes in the regulatory environment in the PRC since the amendment
that was filed on June 7, 2023, warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample
Letters to China-Based Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence
your operations at any time, or may exert control over operations of your business, which could result in a material change in your operations
and/or the value of the securities you are registering for sale. We remind you that, pursuant to federal securities rules, the term “control”
(including the terms “controlling,” “controlled by,” and “under common control with”) as defined in
Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or cause the direction of the management
and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.” The Sample Letters also
sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China can
change quickly with little advance notice. We do not believe that your revised disclosure conveys the same risk. Please restore your disclosures
in these areas to the disclosures as they existed in the registration statement as of June 7, 2023.

Response: In response to the Staff’s
comment, we revised our disclosure throughout Amendment No. 5 to the Registration Statement to restore our disclosures in the above-mentioned
areas.

We thank the Staff for its review of the foregoing.
If you have further comments, we ask that you forward them by electronic mail to our counsel, Ying Li at yli@htflawyers.com or by telephone
at 212-530-2206.

    Very truly yours,

    /s/ Shaofang Weng

    Shaofang Weng

    Chief Executive Officer

    cc:
    Ying Li, Esq.

    Hunter Taubman Fischer & Li LLC