SEC Comment Letter 0000000000-23-003086 to Wetour Robotics Ltd (WETO)
Wetour Robotics Ltd
Date: March 28, 2023 · CIK: 0001941158 · Accession: 0000000000-23-003086
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-269684
Letter
United States securities and exchange commission logo March 28, 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. 1 to Registration Statement on Form F-1 Filed March 17, 2023 File No. 333-269684 Dear Zheng Nan: We have reviewed your amended 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Amendment No. 1 to Registration Statement on Form F-1 Use of Proceeds, page 63 1.We note your disclosure that you plan to use approximately $3.0 million of the proceeds for general corporate purposes and approximately $8.0 million of the proceeds for working capital for your China operations, including but not limited to sale and marketing expenses, and research and development expenses for your Wetour digital platform related products and services. Please revise to more specifically identify the principal intended uses of the net proceeds and provide the estimated amount you intend to allocate to each identified purpose. For example, discuss if any of the proceeds will be used to advance the "Business Strategies" disclosed on page 4. If you do not have a current specific plan for the proceeds of this offering, please discuss the principal reasons for offering and how you determined the size of the offering. Refer to Item 4.A of Form F-1
FirstName LastNameZheng Nan Comapany NameWebus International Ltd. March 28, 2023 Page 2 FirstName LastName Zheng Nan Webus International Ltd. March 28, 2023 Page 2 and Item 3.C of Item 20-F. Index to Consolidated Financial Statements Note 13. Subsequent Event, page F-48 2.Please update the date through which subsequent events were evaluated. Refer to ASC 855-10-50-1 and ASC 855-10-S99-2. 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
March 28, 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. 1 to Registration Statement on Form F-1
Filed March 17, 2023
File No. 333-269684
Dear Zheng Nan:
We have reviewed your amended 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-1
Use of Proceeds, page 63
1.We note your disclosure that you plan to use approximately $3.0 million of the proceeds
for general corporate purposes and approximately $8.0 million of the proceeds for
working capital for your China operations, including but not limited to sale and marketing
expenses, and research and development expenses for your Wetour digital platform
related products and services. Please revise to more specifically identify the principal
intended uses of the net proceeds and provide the estimated amount you intend to allocate
to each identified purpose. For example, discuss if any of the proceeds will be used to
advance the "Business Strategies" disclosed on page 4. If you do not have a current
specific plan for the proceeds of this offering, please discuss the principal reasons for
offering and how you determined the size of the offering. Refer to Item 4.A of Form F-1
FirstName LastNameZheng Nan
Comapany NameWebus International Ltd.
March 28, 2023 Page 2
FirstName LastName
Zheng Nan
Webus International Ltd.
March 28, 2023
Page 2
and Item 3.C of Item 20-F.
Index to Consolidated Financial Statements
Note 13. Subsequent Event, page F-48
2.Please update the date through which subsequent events were evaluated. Refer to ASC
855-10-50-1 and ASC 855-10-S99-2.
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.