SEC Comment Letter 0000000000-23-007909 to Autozi Internet Technology (Global) Ltd. (AZI)
Autozi Internet Technology (Global) Ltd.
Date: July 24, 2023 · CIK: 0001959726 · Accession: 0000000000-23-007909
AI Filing Summary & Sentiment
File numbers found in text: 333-273166
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United States securities and exchange commission logo
July 24, 2023
Houqi Zhang
Chief Executive Officer
Autozi Internet Technology (Global) Ltd.
Block A, Building No. 16
Yonyou Software Park, No. 68 Beiqing Road
Haidian District, Beijing, China
Re:Autozi Internet Technology (Global) Ltd.
Registration Statement on Form F-1
Filed July 7, 2023
File No. 333-273166
Dear Houqi Zhang:
We have reviewed your 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.
Form F-1 Filed July 7, 2023
Prospectus Summary, page 1
1.We note your statement that you "are one of the leading and fast-growing lifecycle
automotive service providers in China." Please revise to disclose the metric(s) by which
such statement is measured. Please revise to disclose the basis for this statement and the
metric by which you have made this determination. If the statement is based
upon management“s belief, please indicate that this is the case and include an explanation
for the basis of the belief.
Related Party Transactions, page 198
2.Please revise to include related party disclosure through the date of the prospectus. As a
FirstName LastNameHouqi Zhang
Comapany NameAutozi Internet Technology (Global) Ltd.
July 24, 2023 Page 2
FirstName LastName
Houqi Zhang
Autozi Internet Technology (Global) Ltd.
July 24, 2023
Page 2
related matter, remove the footnote that indicates subsequent information is limited to
"...the period from October 1, 2022 to April 30, 2023." Refer to Item 7.B of Form 20- F.
Exhibit Index
Exhibit 23.1, page II-5
3.Please ensure the consent refers to the proper filing. For example, it presently refers to
"Amendment No. 3 to Form F-1" but this filing has not yet been amended as a public
filing to this point in time.
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.
You may contact Keira Nakada at 202-551-3659 or Doug Jones at 202-551-3309 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jennie Beysolow at 202-551-8108 or Lilyanna Peyser at 202-551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Yang Ge, Esq.