Correspondence 0001013762-24-003144 from U Power Ltd (UCAR)
U Power Ltd
Date: July 31, 2024 · CIK: 0001939780 · Accession: 0001013762-24-003144
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-41679
Referenced dates: July 12, 2024
Letter
Via Edgar Division of Corporation Finance Office of Manufacturing Form 20-F for the Fiscal Year Ended December 31, 2023 Filed May 15, 2024 File No. 001-41679
Re: U Power Limited
Dear Ms. Yang:
This letter is in response to the letter dated July 12, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed to U Power Limited (the “Company”, “we”, or “our”). For ease of reference, we have recited the Commission’s comments in this response.
Form 20-F for the Fiscal Year Ended December 31, 2023
We have incurred substantial losses in the past..., page 27
1. We note your disclosures that there is substantial doubt about your ability to continue as a going concern and that your auditor indicated in its report on your financial statements for the fiscal year ended December 31, 2023 that there is substantial doubt as to your ability to continue as a going concern for the next 12 months from the date of issuance of the consolidated financial statements. However, we note that your auditor’s report does not include a going concern paragraph and the disclosures on page F-20 state that the substantial doubt of the ability to continue as a going concern is alleviated. Please advise or revise future filings to clarify these inconsistencies.
Response: We acknowledge the Staff’s comment and will revise future filings to clarify these inconsistencies.
Item 15. Controls and Procedures
Management’s Annual Report on Internal Control over Financial Reporting, page 112
2. We note that in the course of preparing your consolidated financial statements for the year ended December 31, 2023, you identified material weaknesses; however, you do not include a statement as to whether your internal control over financial reporting is effective as required by Item 308(a)(3) of Regulation S-K. Please revise future filings to include a statement as to whether ICFR is effective.
Response: We acknowledge the Staff’s comment and will revise future filings to include a statement as to whether our internal control over financial reporting is effective as required by Item 308(a)(3) of Regulation S-K.
We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.
Very truly yours,
/s/ Bingyi Zhao
Show Raw Text
CORRESP
1
filename1.htm
July 31, 2024
Via Edgar
Ms. Stephany Yang
Division of Corporation Finance
Office of Manufacturing
U.S. Securities and Exchange Commission
Re:
U Power Limited
Form 20-F for the Fiscal Year Ended December
31, 2023
Filed May 15, 2024
File No. 001-41679
Dear Ms. Yang:
This letter is in response to the letter dated
July 12, 2024, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
addressed to U Power Limited (the “Company”, “we”, or “our”). For ease of reference, we have recited
the Commission’s comments in this response.
Form 20-F for the Fiscal Year Ended December
31, 2023
We have incurred substantial losses in the
past..., page 27
1. We note your disclosures that there is substantial
doubt about your ability to continue as a going concern and that your auditor indicated in its report on your financial statements for
the fiscal year ended December 31, 2023 that there is substantial doubt as to your ability to continue as a going concern for the next
12 months from the date of issuance of the consolidated financial statements. However, we note that your auditor’s report does not include
a going concern paragraph and the disclosures on page F-20 state that the substantial doubt of the ability to continue as a going concern
is alleviated. Please advise or revise future filings to clarify these inconsistencies.
Response: We acknowledge the Staff’s
comment and will revise future filings to clarify these inconsistencies.
Item 15. Controls and Procedures
Management’s Annual Report on Internal Control
over Financial Reporting, page 112
2. We note that in the course of preparing
your consolidated financial statements for the year ended December 31, 2023, you identified material weaknesses; however, you do not include
a statement as to whether your internal control over financial reporting is effective as required by Item 308(a)(3) of Regulation S-K.
Please revise future filings to include a statement as to whether ICFR is effective.
Response: We acknowledge the Staff’s
comment and will revise future filings to include a statement as to whether our internal control over financial reporting is effective
as required by Item 308(a)(3) of Regulation S-K.
We appreciate the assistance the Staff has provided
with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer &
Li LLC, at (212) 530-2206.
Very truly yours,
/s/ Bingyi Zhao
Name:
Bingyi Zhao
Title:
Chief Financial Officer
Cc: Ying Li, Esq.
Hunter Taubman Fischer & Li LLC