SEC Comment Letter 0000000000-22-013152 to ETAO International Co., Ltd. (ETAOF) (CIK 0001939696)
ETAO International Co., Ltd. (ETAOF) (CIK 0001939696)
Date: Dec. 6, 2022 · CIK: 0001939696 · Accession: 0000000000-22-013152
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo December 6, 2022 Wensheng Liu Chief Executive Officer ETAO International Co., Ltd. 1460 Broadway, 14th Floor New York, NY 10036 Re:ETAO International Co., Ltd. Amendment No. 3 to Draft Registration Statement on Form F-4 Submitted November 29, 2022 CIK 0001939696 Dear Wensheng Liu: We have reviewed your amended draft registration statement and have the following comment. In our comment, 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 comment applies 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 the comment and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 3 to Draft Registration Statement on Form F-4 submitted November 29, 2022 Intellectual Property, page 226 1.We note your response to our prior comment 5. Please revise your statement that ETAO and the VIEs had registered 28 patents to segregate issued patents and patent applications and disclose the typical duration of patent rights in China for inventions.
FirstName LastNameWensheng Liu Comapany NameETAO International Co., Ltd. December 6, 2022 Page 2 FirstName LastName Wensheng Liu ETAO International Co., Ltd. December 6, 2022 Page 2 You may contact Tracie Mariner at 202-551-3744 or Sasha Parikh at 202-551-3627 if you have questions regarding comments on the financial statements and related matters. Please contact Jordan Nimitz at 202-551-5831 or Christine Westbrook at 202-551-5019 with any other questions. Sincerely, Division of Corporation Finance Office of Industrial Applications and Services cc: Mitchell Nussbaum, Esq.
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United States securities and exchange commission logo
December 6, 2022
Wensheng Liu
Chief Executive Officer
ETAO International Co., Ltd.
1460 Broadway, 14th Floor
New York, NY 10036
Re:ETAO International Co., Ltd.
Amendment No. 3 to Draft Registration Statement on Form F-4
Submitted November 29, 2022
CIK 0001939696
Dear Wensheng Liu:
We have reviewed your amended draft registration statement and have the following
comment. In our comment, 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 comment applies 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 the comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form F-4 submitted November 29, 2022
Intellectual Property, page 226
1.We note your response to our prior comment 5. Please revise your statement that ETAO
and the VIEs had registered 28 patents to segregate issued patents and patent applications
and disclose the typical duration of patent rights in China for inventions.
FirstName LastNameWensheng Liu
Comapany NameETAO International Co., Ltd.
December 6, 2022 Page 2
FirstName LastName
Wensheng Liu
ETAO International Co., Ltd.
December 6, 2022
Page 2
You may contact Tracie Mariner at 202-551-3744 or Sasha Parikh at 202-551-3627 if
you have questions regarding comments on the financial statements and related matters. Please
contact Jordan Nimitz at 202-551-5831 or Christine Westbrook at 202-551-5019 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services
cc: Mitchell Nussbaum, Esq.