Correspondence 0001104659-22-127438 from ETAO International Co., Ltd. (ETAOF) (CIK 0001939696)
ETAO International Co., Ltd. (ETAOF) (CIK 0001939696)
Date: Dec. 15, 2022 · CIK: 0001939696 · Accession: 0001104659-22-127438
AI Filing Summary & Sentiment
Referenced dates: December 6, 2022
Letter
Via EDGAR Division of Corporation Finance Office of Manufacturing Re: ETAO International Co., Ltd. Draft Registration Statement on Form F-4 Submitted November 29, 2022 CIK 0001939696
Dear Ms.Nimitz and Ms. Westbrook:
On behalf of ETAO International Co., Ltd. (the “Company”), we are hereby responding to the letter dated December 6, 2022 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), regarding the Company’s Draft Registration Statement on Form F-4 confidentially submitted to the Commission on November 29, 2022 (the “Draft Registration Statement”). In response to the Comment Letter and to update certain information in the Draft Registration Statement, the Company is submitting a revised registration statement on Form F-4 (the “Revised Registration Statement”) to the Commission today.
For ease of reference, the text of the Staff’s comment is included in bold-face type below, followed by the Company’s response.
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.
RESPONSE: The Company acknowledges the Staff’s comment and has revised disclosures on pages 229 - 241 of the Revised Registration Statement.
Please call Andrei Sirabionian of Loeb & Loeb LLP at (212) 407-4089 or Huan Lou of Sichenzia Ross Ference LLP at (212) 930-9700 if you would like additional information with respect to any of the foregoing. Thank you.
Sincerely,
/s/ Loeb & Loeb LLP
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345 Park Avenue
New York, NY 10154
Main 212.407.4000
Fax 212.407.4990
jwww.loeb.com
December 15, 2022
Via EDGAR
Division of Corporation Finance
Office of Manufacturing
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Attn:
Jordan Nimitz
Christine Westbrook
Re:
ETAO International Co., Ltd.
Draft Registration Statement on Form F-4
Submitted November 29, 2022
CIK 0001939696
Dear Ms.Nimitz and Ms. Westbrook:
On behalf of ETAO International Co., Ltd.
(the “Company”), we are hereby responding to the letter dated December 6, 2022 (the “Comment Letter”) from the
staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), regarding the Company’s
Draft Registration Statement on Form F-4 confidentially submitted to the Commission on November 29, 2022 (the “Draft Registration
Statement”). In response to the Comment Letter and to update certain information in the Draft Registration Statement, the Company
is submitting a revised registration statement on Form F-4 (the “Revised Registration Statement”) to the Commission today.
For ease of reference, the text of the Staff’s
comment is included in bold-face type below, followed by the Company’s response.
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.
RESPONSE:
The Company acknowledges the Staff’s comment and has revised disclosures on pages 229 - 241 of the Revised Registration Statement.
Please call Andrei Sirabionian of Loeb &
Loeb LLP at (212) 407-4089 or Huan Lou of Sichenzia Ross Ference LLP at (212) 930-9700 if you would like additional information with respect
to any of the foregoing. Thank you.
Sincerely,
/s/ Loeb & Loeb LLP
Loeb & Loeb LLP