SEC Comment Letter 0000000000-23-000424 to Haoxin Holdings Ltd (HXHX)
Haoxin Holdings Ltd
Date: Jan. 17, 2023 · CIK: 0001936817 · Accession: 0000000000-23-000424
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Letter
United States securities and exchange commission logo January 17, 2023 Zhengjun Tao Chief Executive Officer Haoxin Holdings Limited Room 329-1, 329-2, No.1 Xingye Yi Road Ningbo Free Trade Zone Ningbo, Zhejiang Province 315807 People's Republic of China Re:Haoxin Holdings Limited Amendment No. 2 to Draft Registration Statement on Form F-1 Submitted December 23, 2022 CIK No. 0001936817 Dear Zhengjun Tao: We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. 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 the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Draft Registration Statement on Form F-1 submitted December 23, 2022 Risk Factors Our business could be materially harmed by the ongoing coronavirus (COVID-19) pandemic, page 45 1.Please update your risk factor disclosure with respect to any material risks related to the COVID-19 pandemic. For example, we note your disclosure that your workforce remains stable during 2020, 2021 and the first half of 2022.
FirstName LastNameZhengjun Tao Comapany NameHaoxin Holdings Limited January 17, 2023 Page 2 FirstName LastName Zhengjun Tao Haoxin Holdings Limited January 17, 2023 Page 2 ENFORCEABILITY OF CIVIL LIABILITIES, page 171 2.We note your disclosure that a majority of your directors and officers are nationals and/or residents of countries and areas other than the United States, including the PRC and Hong Kong. Please revise to clarify those of your officers and directors who are located in the PRC and those that are located in Hong Kong. You may contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Lily Dang, Staff Accountant, at 202-551-3867 if you have questions regarding comments on the financial statements and related matters. Please contact Liz Packebusch, Staff Attorney, at 202-551-8749 or Laura Nicholson, Special Counsel, at 202-551-3584 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: William S. Rosenstadt
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United States securities and exchange commission logo
January 17, 2023
Zhengjun Tao
Chief Executive Officer
Haoxin Holdings Limited
Room 329-1, 329-2, No.1 Xingye Yi Road
Ningbo Free Trade Zone
Ningbo, Zhejiang Province 315807
People's Republic of China
Re:Haoxin Holdings Limited
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted December 23, 2022
CIK No. 0001936817
Dear Zhengjun Tao:
We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted December 23, 2022
Risk Factors
Our business could be materially harmed by the ongoing coronavirus (COVID-19) pandemic,
page 45
1.Please update your risk factor disclosure with respect to any material risks related to the
COVID-19 pandemic. For example, we note your disclosure that your workforce remains
stable during 2020, 2021 and the first half of 2022.
FirstName LastNameZhengjun Tao
Comapany NameHaoxin Holdings Limited
January 17, 2023 Page 2
FirstName LastName
Zhengjun Tao
Haoxin Holdings Limited
January 17, 2023
Page 2
ENFORCEABILITY OF CIVIL LIABILITIES, page 171
2.We note your disclosure that a majority of your directors and officers are nationals and/or
residents of countries and areas other than the United States, including the PRC and Hong
Kong. Please revise to clarify those of your officers and directors who are located in the
PRC and those that are located in Hong Kong.
You may contact Joseph Klinko, Staff Accountant, at 202-551-3824 or Lily Dang, Staff
Accountant, at 202-551-3867 if you have questions regarding comments on the financial
statements and related matters. Please contact Liz Packebusch, Staff Attorney, at 202-551-8749
or Laura Nicholson, Special Counsel, at 202-551-3584 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: William S. Rosenstadt