SEC Comment Letter 0000000000-23-009176 to Harden Technologies Inc. (HAHA) (CIK 0001873723)
Harden Technologies Inc. (HAHA) (CIK 0001873723)
Date: Aug. 22, 2023 · CIK: 0001873723 · Accession: 0000000000-23-009176
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File numbers found in text: 333-269755
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United States securities and exchange commission logo
August 22, 2023
Jiawen Miao
Chief Executive Officer
Harden Technologies Inc.
Building 8, No. 6 Jingye Road
Zhongshan City
PR China 528400
Re:Harden Technologies Inc.
Amendment No. 3 to Registration Statement on Form F-1
Filed August 4, 2023
File No. 333-269755
Dear Jiawen Miao:
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 July 28, 2023 letter.
Amendment No. 3 to Form F-1
Note 3. Short-term Investment, page F-19
1.We note your response to our prior comment. Please enhance the description of the
composition of your short-term investment; for example, disclose the precise type of
“wealth management financial product with variable interest rate referenced to
performance of underlying assets issued by Industrial Bank ” (e.g., equities, fixed income,
or alternative investments, such as structured notes, etc.). Also, disclose what the range of
the variable rate of interest is and how the variable interest is referenced to the underlying
asset.
FirstName LastNameJiawen Miao
Comapany NameHarden Technologies Inc.
August 22, 2023 Page 2
FirstName LastName
Jiawen Miao
Harden Technologies Inc.
August 22, 2023
Page 2
General
2.We note the changes you made to your disclosure appearing on the cover page, 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 July 13, 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.
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 referencing the PRC
government’s intent to strengthen its regulatory oversight conveys the same risk. Please
revise.
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, Staff
Attorney, 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