SEC Comment Letter 0000000000-24-000185 to ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)
ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)
Date: Jan. 5, 2024 · CIK: 0001954042 · Accession: 0000000000-24-000185
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File numbers found in text: 333-275427
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United States securities and exchange commission logo
January 5, 2024
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. 2 to Registration Statement on Form F-1
Filed on December 29, 2023
File No. 333-275427
Dear Jing Yuan:
We have reviewed your amended registration statement and have the following
comments.
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. Unless we note otherwise,
any references to prior comments are to comments in our November 30, 2023 letter.
Form F-1 filed December 29, 2023
General
1.We note your response to our prior comment 3 and reissue in part. Please revise your risk
factors to discuss the arbitration provision's 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.
FirstName LastNameJing Yuan
Comapany NameZEEKR Intelligent Technology Holding Ltd
January 5, 2024 Page 2
FirstName LastName
Jing Yuan
ZEEKR Intelligent Technology Holding Ltd
January 5, 2024
Page 2
2.Please update your compensation disclosure to reflect the fiscal year ended December 31,
2023.
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