Correspondence 0001213900-24-078579 from Huachen AI Parking Management Technology Holding Co., Ltd (HCAI)
Huachen AI Parking Management Technology Holding Co., Ltd
Date: Sept. 13, 2024 · CIK: 0001958399 · Accession: 0001213900-24-078579
AI Filing Summary & Sentiment
Referenced dates: August 26, 2024
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CORRESP
1
filename1.htm
September 13, 2024
Via EDGAR
Division of Corporation Finance
Office of Manufacturing
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C., 20549
Attention:
Bradley Ecker
Jennifer Angelini
SiSi Cheng
Andrew Blume
Re:
Huachen AI Parking Management Technology Holding Co., Ltd
Registration Statement on Form F-1
Submitted August 14, 2024
CIK No. 0001958399
Ladies and Gentlemen:
This letter is being submitted in response to
the letter dated August 26, 2024 from the U.S. Securities and Exchange Commission (the “Commission”) in which the staff
of the Commission (the “Staff”) commented on the above-referenced Registration Statement on Form F-1 submitted on August
14, 204. Concurrently with the submission of this letter, we hereby transmit, via EDGAR, an amended Registration Statement on Form F-1
(“F-1/A”) for filing with the Commission, which has been revised to reflect the Staff’s comments as well as certain
other updates to the F-1/A.
For the Staff’s convenience, the Staff’s
comment has been stated below in its entirety, with the Company’s response set out immediately underneath such comment. Page references
below in the Company’s responses are to the page numbers in F-1/A. Capitalized terms used but not otherwise defined herein have
the meanings set forth in the F-1/A.
Registration Statement on Form F-1 filed August
14, 2024
Capitalization, page 47
1.
Your total capitalization amounts do not appear to be calculated correctly. Please revise your disclosures accordingly.
Response: In response to the
Staff’s comment, we have revised our disclosure in the capitalization section.
We hope this response has addressed all the Staff’s
concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact
our securities counsel William S. Rosenstadt, Esq., Mengyi “Jason” Ye, Esq. or Yuning “Grace” Bai, Esq. of Ortoli
Rosenstadt LLP at wsr@orllp.legal, jye@orllp.legal or gbai@orllp.legal.
Very truly yours,
/s/ Bin Lu
Bin Lu