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SEC Comment Letter 0000000000-24-004169 to ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)

ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)
Date: April 17, 2024 · CIK: 0001954042 · Accession: 0000000000-24-004169

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File numbers found in text: 333-275427

Date
April 17, 2024
Author
Jing Yuan
Form
UPLOAD
Company
ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)

Letter

United States securities and exchange commission logo April 17, 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. 4 to Registration Statement on Form F-1 Filed on April 12, 2024 File No. 333-275427 Dear Jing Yuan: We have reviewed your amended registration statement and have the following comment. 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 March 27, 2024 letter. Form F-1/A filed April 12, 2024 Capitalization, page 82 1.We note your response to our comment number 1; however, your Consolidated Balance Sheet for the year ended December 31, 2023 (on page F-4) indicates notes payable of US$ 775,355 and amounts due to related parties of US$ 2,303,681. It is not clear why the aforementioned indebtedness is not included in the Capitalization table. Please refer to Part I, Item 3 (B) and the related instructions to Form 20-F and revise as necessary. 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.

FirstName LastNameJing Yuan Comapany NameZEEKR Intelligent Technology Holding Ltd April 17, 2024 Page 2 FirstName LastName Jing Yuan ZEEKR Intelligent Technology Holding Ltd April 17, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Manufacturing cc: Li He

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United States securities and exchange commission logo
April 17, 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. 4 to Registration Statement on Form F-1
Filed on April 12, 2024
File No. 333-275427
Dear Jing Yuan:
            We have reviewed your amended registration statement and have the following comment.
            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 March 27, 2024 letter.
Form F-1/A filed April 12, 2024
Capitalization, page 82
1.We note your response to our comment number 1; however, your Consolidated Balance
Sheet for the year ended December 31, 2023 (on page F-4) indicates notes payable of US$
775,355 and amounts due to related parties of US$ 2,303,681. It is not clear why the
aforementioned indebtedness is not included in the Capitalization table. Please refer to
Part I, Item 3 (B) and the related instructions to Form 20-F and revise as necessary.
            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.

 FirstName LastNameJing Yuan
 Comapany NameZEEKR Intelligent Technology Holding Ltd
 April 17, 2024 Page 2
 FirstName LastName
Jing Yuan
ZEEKR Intelligent Technology Holding Ltd
April 17, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Li He