SEC Comment Letter 0000000000-23-003835 to Wetour Robotics Ltd (WETO)
Wetour Robotics Ltd
Date: April 17, 2023 · CIK: 0001941158 · Accession: 0000000000-23-003835
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File numbers found in text: 333-269684
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United States securities and exchange commission logo
April 17, 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. 2 to Registration Statement on Form F-1
Filed April 4, 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. 2 to Registration Statement on Form F-1
Cover Page
1.We note your disclosure here and elsewhere in your prospectus regarding the Trial
Administrative Measures of Overseas Securities Offering and Listing by Domestic
Enterprises, which you term the "New Overseas Listing Rules." As these Trial Measures
became effective on March 31, 2023, please update your disclosure and disclose how, if at
all, the Trial Measures apply to this transaction, whether you and relevant parties to this
transaction have complied with your obligations under the Trial Measures, and the risks to
investors of non-compliance.
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
FirstName LastNameZheng Nan
Comapany NameWebus International Ltd.
April 17, 2023 Page 2
FirstName LastName
Zheng Nan
Webus International Ltd.
April 17, 2023
Page 2
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.