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July 11, 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 Registration Statement on Form F-1
Filed June 29, 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. 3 to Registration Statement on Form F-1
Risk Factors
Any change of regulations and rules by Chinese government including potential additional
requirements on cybersecurity review..., page 53
1. We note your disclosure on the "Measures for Security Assessment for Outbound Data
Transfer", which became effective on September 1, 2022.  You further disclose that as of
the date of this prospectus, you have not transferred any user information to places outside
of the PRC.  In this regard, you also disclose that as advised by AllBright, you are not
currently subject to the outbound data transfer regulations because "Chinese customers
using [y]our services must provide their information on Wetour’s website and
applications, which were established and maintained in the U.S. Therefore, there is no
data transferred across the border of PRC by [you]." However, you also disclose that your

 FirstName LastNameZheng Nan
 Comapany NameWebus International Ltd.
 July 11, 2023 Page 2
 FirstName LastName
Zheng Nan
Webus International Ltd.
July 11, 2023
Page 2
PRC users may have the potential needs to make reservations inside PRC and enjoy travel
services overseas. Under such circumstances, you disclose that you may need to transfer
user data outside of the PRC to "Wetour" or your overseas business partners to satisfy
your PRC users’ needs and that such user data is mainly the user’s information required
for reservation such as the user’s name and contact information which you believe is not
Important Data or sensitive personal information. You disclose though, that if you
cumulatively transfer abroad the personal information of more than 100,000 PRC users,
you believe you will be subject to assessment by the CAC. If you are subject to
assessment by the CAC for any reason, and you fail to pass such assessment and/or to
comply with the data privacy and data security requirements raised during such
assessment, you disclose that you could be subject to penalties, and incur damage to your
reputation and brand, and harm your business and the results of operations. Please explain
in greater detail the the nature of the penalties your company and/or its officers and
directors may incur if you fail to pass a CAC assessment and/or are deemed non-
compliant with the data privacy and data security requirements raised during such
assessment, and any related impact on your results of operations.
            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.