SEC Comment Letter 0000000000-23-007365 to U-BX Technology Ltd. (UBXG) (CIK 0001888525) (UBXG)
U-BX Technology Ltd. (UBXG) (CIK 0001888525)
Date: July 11, 2023 · CIK: 0001888525 · Accession: 0000000000-23-007365
AI Filing Summary & Sentiment
File numbers found in text: 333-262412
Letter
United States securities and exchange commission logo July 11, 2023 Mingfei Liu Chief Operating Officer U-BX Technology Ltd. Zhongguan Science and Technology Park No. 1 Linkong Er Road, Shunyi District, Beijing People’s Republic of China Re:U-BX Technology Ltd. Amendment No. 13 to Registration Statement on Form F-1 Filed June 27, 2023 File No. 333-262412 Dear Mingfei Liu: 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 April 26, 2023 letter. Amendment No. 13 to Registration Statement on Form F-1 General 1.It appears that the last year of audited financial statements will be older than 12 months at the time of the offering. Accordingly, please update the last year of audited financial statements. Refer to Item 8.A.4 of Form 20-F and the corresponding instructions, which indicate that audited financial statements should generally not be older than 12 months at the time of filing, but also indicate audited financial statements not older than 15 months may be permitted if a company is able to represent the following:
FirstName LastNameMingfei Liu Comapany NameU-BX Technology Ltd. July 11, 2023 Page 2 FirstName LastName Mingfei Liu U-BX Technology Ltd. July 11, 2023 Page 2 • The company is not required to comply with the 12 month requirement for the age of financial statements in any other jurisdiction outside the United States; and • Complying with the 12 month requirement is impracticable or involves undue hardship.
If you meet the above criteria, please provide a representation from management that says you meet the criteria and file that representation as an exhibit to your registration statement. If you do not meet the criteria, please provide updated audited financial statements and related disclosures. You may contact Morgan Youngwood, Senior Staff Accountant, at (202) 551-3479 or Stephen Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding comments on the financial statements and related matters. Please contact Matthew Crispino, Staff Attorney, at (202) 551-3456 or Matthew Derby, Legal Branch Chief, at (202) 551-3334 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: William S. Rosenstadt
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United States securities and exchange commission logo
July 11, 2023
Mingfei Liu
Chief Operating Officer
U-BX Technology Ltd.
Zhongguan Science and Technology Park
No. 1 Linkong Er Road, Shunyi District, Beijing
People’s Republic of China
Re:U-BX Technology Ltd.
Amendment No. 13 to Registration Statement on Form F-1
Filed June 27, 2023
File No. 333-262412
Dear Mingfei Liu:
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 April 26, 2023 letter.
Amendment No. 13 to Registration Statement on Form F-1
General
1.It appears that the last year of audited financial statements will be older than 12 months at
the time of the offering. Accordingly, please update the last year of audited financial
statements. Refer to Item 8.A.4 of Form 20-F and the corresponding instructions, which
indicate that audited financial statements should generally not be older than 12 months at
the time of filing, but also indicate audited financial statements not older than 15 months
may be permitted if a company is able to represent the following:
FirstName LastNameMingfei Liu
Comapany NameU-BX Technology Ltd.
July 11, 2023 Page 2
FirstName LastName
Mingfei Liu
U-BX Technology Ltd.
July 11, 2023
Page 2
• The company is not required to comply with the 12 month requirement for the age of
financial statements in any other jurisdiction outside the United States; and
• Complying with the 12 month requirement is impracticable or involves undue hardship.
If you meet the above criteria, please provide a representation from management that says
you meet the criteria and file that representation as an exhibit to your registration
statement. If you do not meet the criteria, please provide updated audited financial
statements and related disclosures.
You may contact Morgan Youngwood, Senior Staff Accountant, at (202) 551-3479 or
Stephen Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions regarding
comments on the financial statements and related matters. Please contact Matthew Crispino,
Staff Attorney, at (202) 551-3456 or Matthew Derby, Legal Branch Chief, at (202) 551-3334
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: William S. Rosenstadt