SEC Comment Letter 0000000000-25-003369 to EShallGo Inc. (EHGO)

EShallGo Inc.
Date: March 28, 2025 · CIK: 0001879754 · Accession: 0000000000-25-003369

View on Edgar

AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

File numbers found in text: 001-42154

Date

March 28, 2025

Author

Division of

Form

UPLOAD

Company

EShallGo Inc.

Letter

Re: EShallGo Inc. Annual Report on Form 20-F Filed July 31, 2024 File No. 001-42154 Dear Qiwei Miao:

March 28, 2025

Qiwei Miao Chief Executive Officer EShallGo Inc. 12F Block 16, No.1000 Jinhai Road Pudong New District Shanghai , China 201206

We have reviewed your filing and have the following comment.

Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Annual Report on Form 20-F Filed July 31, 2024 General

1. Please provide more specific and prominent disclosures about the legal and operational risks associated with China-based companies. To the extent the Division of Corporation Finance s Sample Letter to China-Based Companies, issued by the Staff in December 2021, requests disclosure on the prospectus cover page or in the prospectus summary, please provide such disclosure in a separate section at the beginning of Item 3 of Form 20-F. For example, include disclosure regarding the legal and operational risks, permissions and approvals that you, your subsidiaries or the VIEs are required to obtain from Chinese authorities to operate your business as well as summary risk factors. In addition, include a discussion of the transfer of cash within the company in Item 5 of Form 20-F. Please explain to us how you will revise future filings to comply with our comment by providing us with a response letter with your proposed disclosures. March 28, 2025 Page 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.

Please contact Scott Anderegg at 202-551-3342 or Cara Wirth at 202-551-7127 with any questions.

Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Qiwei Miao

Show Raw Text

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 28, 2025

Qiwei Miao
Chief Executive Officer
EShallGo Inc.
12F Block 16, No.1000 Jinhai Road
Pudong New District
Shanghai , China 201206

 Re: EShallGo Inc.
 Annual Report on Form 20-F
 Filed July 31, 2024
 File No. 001-42154
Dear Qiwei Miao:

 We have reviewed your filing and have the following comment.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Annual Report on Form 20-F Filed July 31, 2024
General

1. Please provide more specific and prominent disclosures about the legal
and
 operational risks associated with China-based companies. To the extent
the Division
 of Corporation Finance s Sample Letter to China-Based Companies,
issued by the
 Staff in December 2021, requests disclosure on the prospectus cover page
or in the
 prospectus summary, please provide such disclosure in a separate section
at the
 beginning of Item 3 of Form 20-F. For example, include disclosure
regarding the legal
 and operational risks, permissions and approvals that you, your
subsidiaries or the
 VIEs are required to obtain from Chinese authorities to operate your
business as well
 as summary risk factors. In addition, include a discussion of the
transfer of cash
 within the company in Item 5 of Form 20-F. Please explain to us how you
will revise
 future filings to comply with our comment by providing us with a
response letter with
 your proposed disclosures.
 March 28, 2025
Page 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.

 Please contact Scott Anderegg at 202-551-3342 or Cara Wirth at
202-551-7127 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Qiwei Miao
</TEXT>
</DOCUMENT>

SecProbe.io