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SEC Comment Letter 0000000000-24-007841 to Wetour Robotics Ltd (WETO)

Wetour Robotics Ltd
Date: July 10, 2024 · CIK: 0001941158 · Accession: 0000000000-24-007841

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File numbers found in text: 333-269684

Date
July 10, 2024
Author
Zheng Nan
Form
UPLOAD
Company
Wetour Robotics Ltd

Letter

July 10, 2024 Zheng Nan Chief Executive Officer Webus International Ltd. 25/F, UK Center, EFC, Yuhang District Hangzhou, China 311121 Re:Webus International Ltd. Amendment No. 6 to Registration Statement on Form F-1 Filed June 27, 2024 File No. 333-269684 Dear Zheng Nan: We have reviewed your amended registration statement and have the following comment(s). Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Amendment No. 6 to Registration Statement on Form F-1 Exhibits 1.You disclose under Liquidity on page 90 that on April 17, 2024, you entered into a funding support agreement with Mr. Zheng Nan, one of your major shareholders, in which Mr. Zheng Nan promised to provide a line of credit in the amount up to RMB6,000,000 ($845,082) and up to RMB10,000,000 ($1,408,471) as a guarantee for your future bank credit applications. This agreement will expire on December 31, 2025. Please file this funding support agreement as an exhibit, or provide your analysis that such agreement is not required to be filed. See Item 601(b)(10) of Regulation S-K. 2.Please file your Form of Amended and Restated Memorandum and Articles of Association before effectiveness.

July 10, 2024 Page 2 Please 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.

Show Raw Text
July 10, 2024
Zheng Nan
Chief Executive Officer
Webus International Ltd.
25/F, UK Center, EFC, Yuhang District
Hangzhou, China 311121
Re:Webus International Ltd.
Amendment No. 6 to Registration Statement on Form F-1
Filed June 27, 2024
File No. 333-269684
Dear Zheng Nan:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Amendment No. 6 to Registration Statement on Form F-1
Exhibits
1.You disclose under Liquidity on page 90 that on April 17, 2024, you entered into a
funding support agreement with Mr. Zheng Nan, one of your major shareholders, in which
Mr. Zheng Nan promised to provide a line of credit in the amount up to RMB6,000,000
($845,082) and up to RMB10,000,000 ($1,408,471) as a guarantee for your future bank
credit applications. This agreement will expire on December 31, 2025. Please file this
funding support agreement as an exhibit, or provide your analysis that such agreement is
not required to be filed. See Item 601(b)(10) of Regulation S-K.
2.Please file your Form of Amended and Restated Memorandum and Articles of
Association before effectiveness.

July 10, 2024
Page 2
            Please 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.