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SEC Comment Letter 0000000000-23-001825 to Harden Technologies Inc. (HAHA) (CIK 0001873723)

Harden Technologies Inc. (HAHA) (CIK 0001873723)
Date: Feb. 23, 2023 · CIK: 0001873723 · Accession: 0000000000-23-001825

AI Filing Summary & Sentiment

File numbers found in text: 333-269755

Date
February 23, 2023
Author
Office of Technology
Form
UPLOAD
Company
Harden Technologies Inc. (HAHA) (CIK 0001873723)

Letter

United States securities and exchange commission logo February 23, 2023 Jiawen Miao Chief Executive Officer Harden Technologies Inc. No. 3 Chuangye Road Torch Development Zone Zhongshan City PR China 528400 Re:Harden Technologies Inc. Registration Statement on Form F-1 Filed February 14, 2023 File No. 333-269755 Dear Jiawen Miao: We have reviewed your 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. Form F-1 filed February 14, 2023 Prospectus Conventions, page 16 1.We note that your definition of "China" or the "PRC" excludes Hong Kong and Macau. Please revise your disclosure to remove the exclusion of Hong Kong and Macau from your definition of "China" or the "PRC." Risk Factors, page 21 2.We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively

FirstName LastNameJiawen Miao Comapany NameHarden Technologies Inc. February 23, 2023 Page 2 FirstName LastName Jiawen Miao Harden Technologies Inc. February 23, 2023 Page 2 smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial price volatility and any known factors particular to your offering that may add to this risk and discuss the risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock-run up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock. Consolidated Financial Statements, page F-1 3.We note your filing includes audited financial statements that are older than 12 months. Please provide updated audited financial statements pursuant to Item 8.A.4 of Form 20-F or provide the appropriate representations in an exhibit. Refer to Instruction 2 to Item 8.A.4. Note 17. Subsequent Events, page F-26 4.Please consider and disclose any other non-recognized subsequent event that is of such a nature that it must be disclosed to keep the financial statements from being misleading to investors. Refer to ASC 855-10-50-2. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. You may contact Joseph Cascarano, Senior Staff Accountant, at 202-551-3376 or Robert Littlepage, Accounting Branch Chief, at 202-551-3361 if you have questions regarding comments on the financial statements and related matters. Please contact Marion Graham, Law Clerk, at 202-551-6521 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Bradley A. Haneberg

Show Raw Text
United States securities and exchange commission logo
February 23, 2023
Jiawen Miao
Chief Executive Officer
Harden Technologies Inc.
No. 3 Chuangye Road
Torch Development Zone
Zhongshan City
PR China 528400
Re:Harden Technologies Inc.
Registration Statement on Form F-1
Filed February 14, 2023
File No. 333-269755
Dear Jiawen Miao:
            We have reviewed your 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.
Form F-1 filed February 14, 2023
Prospectus Conventions, page 16
1.We note that your definition of "China" or the "PRC" excludes Hong Kong and Macau.
Please revise your disclosure to remove the exclusion of Hong Kong and Macau from
your definition of "China" or the "PRC."
Risk Factors, page 21
2.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively

 FirstName LastNameJiawen Miao
 Comapany NameHarden Technologies Inc.
 February 23, 2023 Page 2
 FirstName LastName
Jiawen Miao
Harden Technologies Inc.
February 23, 2023
Page 2
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and any known factors particular to your offering that
may add to this risk and discuss the risks to investors when investing in stock where the
price is changing rapidly. Clearly state that such volatility, including any stock-run up,
may be unrelated to your actual or expected operating performance and financial
condition or prospects, making it difficult for prospective investors to assess the rapidly
changing value of your stock.
Consolidated Financial Statements, page F-1
3.We note your filing includes audited financial statements that are older than 12 months.
Please provide updated audited financial statements pursuant to Item 8.A.4 of Form 20-F
or provide the appropriate representations in an exhibit. Refer to Instruction 2 to
Item 8.A.4.
Note 17. Subsequent Events, page F-26
4.Please consider and disclose any other non-recognized subsequent event that is of such a
nature that it must be disclosed to keep the financial statements from being misleading to
investors. Refer to ASC 855-10-50-2.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Joseph Cascarano, Senior Staff Accountant, at 202-551-3376 or Robert
Littlepage, Accounting Branch Chief, at 202-551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact Marion Graham, Law
Clerk, at 202-551-6521 or Jan Woo, Legal Branch Chief, at 202-551-3453 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Bradley A. Haneberg