SEC Comment Letter 0000000000-23-013056 to ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)
ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)
Date: Nov. 30, 2023 · CIK: 0001954042 · Accession: 0000000000-23-013056
AI Filing Summary & Sentiment
File numbers found in text: 333-275427
Letter
United States securities and exchange commission logo November 30, 2023 Jing Yuan Chief Financial Officer ZEEKR Intelligent Technology Holding Ltd No. 1388 Minshan Road Xinqi Street, Beilun District Ningbo, Zhejiang People’s Republic of China Re:ZEEKR Intelligent Technology Holding Ltd Amendment No. 1 to Registration Statement on Form F-1 Filed on November 24, 2023 File No. 333-275427 Dear Jing Yuan: We have reviewed your 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. 1 to Registration Statement on Form F-1 filed November 24, 2023 Recent Developments, page 16 1.Please revise to include your recent developments discussion and analysis prominently within your MD&A. 2.We note you have provided certain selected unaudited combine and consolidated statements of operations data for the nine months ended September 30, 2022 and 2023. Please revise to also include combined and consolidated balance sheets as of September 30, 2023 along with a discussion of your liquidity.
FirstName LastNameJing Yuan Comapany NameZEEKR Intelligent Technology Holding Ltd November 30, 2023 Page 2 FirstName LastName Jing Yuan ZEEKR Intelligent Technology Holding Ltd November 30, 2023 Page 2 General 3.Please revise to discuss the arbitration provisions in Exhibit 4.3 and the related risks to investors, such as increased costs to bring a claim, limited access to information and other imbalances of resources between the company and shareholders, and that the provision can discourage claims or limit shareholders’ ability to bring a claim in a judicial forum that they find favorable. State specifically whether the provisions apply to claims arising under the federal securities laws and whether there is any concerns regarding the enforceability of the provision. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Charles Eastman at 202-551-3794 or Hugh West at 202-551-3872 if you have questions regarding comments on the financial statements and related matters. Please contact Bradley Ecker at 202-551-4985 or Geoffrey Kruczek at 202-551-3641 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Li He
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United States securities and exchange commission logo
November 30, 2023
Jing Yuan
Chief Financial Officer
ZEEKR Intelligent Technology Holding Ltd
No. 1388 Minshan Road
Xinqi Street, Beilun District
Ningbo, Zhejiang
People’s Republic of China
Re:ZEEKR Intelligent Technology Holding Ltd
Amendment No. 1 to Registration Statement on Form F-1
Filed on November 24, 2023
File No. 333-275427
Dear Jing Yuan:
We have reviewed your 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. 1 to Registration Statement on Form F-1 filed November 24, 2023
Recent Developments, page 16
1.Please revise to include your recent developments discussion and analysis prominently
within your MD&A.
2.We note you have provided certain selected unaudited combine and consolidated
statements of operations data for the nine months ended September 30, 2022 and 2023.
Please revise to also include combined and consolidated balance sheets as of September
30, 2023 along with a discussion of your liquidity.
FirstName LastNameJing Yuan
Comapany NameZEEKR Intelligent Technology Holding Ltd
November 30, 2023 Page 2
FirstName LastName
Jing Yuan
ZEEKR Intelligent Technology Holding Ltd
November 30, 2023
Page 2
General
3.Please revise to discuss the arbitration provisions in Exhibit 4.3 and the related risks to
investors, such as increased costs to bring a claim, limited access to information and other
imbalances of resources between the company and shareholders, and that
the provision can discourage claims or limit shareholders’ ability to bring a claim in a
judicial forum that they find favorable. State specifically whether the provisions apply to
claims arising under the federal securities laws and whether there is any concerns
regarding the enforceability of the provision.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Charles Eastman at 202-551-3794 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at 202-551-4985 or Geoffrey Kruczek at 202-551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Li He