SEC Comment Letter 0000000000-23-006137 to HUHUTECH International Group Inc. (HUHU) (CIK 0001945415) (HUHU)
HUHUTECH International Group Inc. (HUHU) (CIK 0001945415)
Date: June 8, 2023 · CIK: 0001945415 · Accession: 0000000000-23-006137
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File numbers found in text: 333-270958
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United States securities and exchange commission logo
June 8, 2023
Yujun Xiao
Chief Executive Officer
HUHUTECH International Group Inc.
3-1208 Tiananzhihui Compound
228 Linghu Road
Xinwu District, Wuxi City, Jiangsu Province
People’s Republic of China 214135
Re:HUHUTECH International Group Inc.
Amended Registration Statement on Form F-1
Filed on May 31, 2023
File No. 333-270958
Dear Yujun Xiao:
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. Unless we note
otherwise, our references to prior comments are to comments in our April 11, 2023 letter.
Amended Form F-1 filed May 31, 2023
Management, page 99
1.Please amend your disclosure to include the annual base salary figure for CFO Huiping
Zhang.
Related Party Transactions, page 102
2.Please file all outstanding loan agreements as exhibits to your registration statement,
including outstanding loans agreements with the Bank of China.
FirstName LastNameYujun Xiao
Comapany NameHUHUTECH International Group Inc.
June 8, 2023 Page 2
FirstName LastName
Yujun Xiao
HUHUTECH International Group Inc.
June 8, 2023
Page 2
You may contact Kevin Stertzel at 202-551-3723 or Claire Erlanger at 202-551-3301 if
you have questions regarding comments on the financial statements and related matters. Please
contact Gregory Herbers at 202-551-8028 or Jay Ingram at 202-551-3397 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Yarona L. Yieh