SEC Comment Letter 0000000000-23-000859 to Wetour Robotics Ltd (WETO)
Wetour Robotics Ltd
Date: Jan. 26, 2023 · CIK: 0001941158 · Accession: 0000000000-23-000859
AI Filing Summary & Sentiment
Reasoning
Letter
United States securities and exchange commission logo January 26, 2023 Zheng Nan Chief Executive Officer Webus International Ltd. 25/F, UK Center, EFC, Yuhang District Hangzhou, China 311121 Re:Webus International Ltd. Amendment No. 3 to Draft Registration Statement on Form F-1 Submitted Janurary 3, 2023 CIK No. 0001941158 Dear Zheng Nan: 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. Unless we note otherwise, our references to prior comments are to comments in our December 22, 2022 letter. Amendment No. 3 to Draft Registration Statement on Form F-1 Cover Page 1.It does not appear you revised disclosure in response to prior comment 1. Refrain from using terms such as “we” or “our” when describing the activities or functions of your VIE throughout the prospectus. In this regard, we note your disclosure on page i that substantially all the company's business is conducted by Youba Tech, the VIE in the PRC, and its subsidiary Webus Travel Agency. Our Industry, page 88 2.It does not appear you revised disclosure in response to prior comment 8. Please revise
FirstName LastNameZheng Nan Comapany NameWebus International Ltd. January 26, 2023 Page 2 FirstName LastName Zheng Nan Webus International Ltd. January 26, 2023 Page 2 your disclosure to include balancing language to emphasize the prospective nature of the CAGR projections you include in this section derived from the Frost & Sullivan report you commissioned in September 2022. You may contact Myra Moosariparambil, Staff Accountant, at (202) 551-3796 or Craig Arakawa, Accounting Branch Chief, at (202) 551-3650 if you have questions regarding comments on the financial statements and related matters. Please contact Irene Barberena- Meissner, Staff Attorney, at (202) 551-6548 or Kevin Dougherty, Staff Attorney, at (202) 551- 3271 with any other questions Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Fang Liu. Esq.
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United States securities and exchange commission logo
January 26, 2023
Zheng Nan
Chief Executive Officer
Webus International Ltd.
25/F, UK Center, EFC, Yuhang District
Hangzhou, China 311121
Re:Webus International Ltd.
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted Janurary 3, 2023
CIK No. 0001941158
Dear Zheng Nan:
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. Unless we note otherwise, our references to prior comments are to comments in our
December 22, 2022 letter.
Amendment No. 3 to Draft Registration Statement on Form F-1
Cover Page
1.It does not appear you revised disclosure in response to prior comment 1. Refrain from
using terms such as “we” or “our” when describing the activities or functions of your VIE
throughout the prospectus. In this regard, we note your disclosure on page i
that substantially all the company's business is conducted by Youba Tech, the VIE in the
PRC, and its subsidiary Webus Travel Agency.
Our Industry, page 88
2.It does not appear you revised disclosure in response to prior comment 8. Please revise
FirstName LastNameZheng Nan
Comapany NameWebus International Ltd.
January 26, 2023 Page 2
FirstName LastName
Zheng Nan
Webus International Ltd.
January 26, 2023
Page 2
your disclosure to include balancing language to emphasize the prospective nature of the
CAGR projections you include in this section derived from the Frost & Sullivan report
you commissioned in September 2022.
You may contact Myra Moosariparambil, Staff Accountant, at (202) 551-3796 or Craig
Arakawa, Accounting Branch Chief, at (202) 551-3650 if you have questions regarding
comments on the financial statements and related matters. Please contact Irene Barberena-
Meissner, Staff Attorney, at (202) 551-6548 or Kevin Dougherty, Staff Attorney, at (202) 551-
3271 with any other questions
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Fang Liu. Esq.