SEC Comment Letter 0000000000-24-007108 to Autozi Internet Technology (Global) Ltd. (AZI)
Autozi Internet Technology (Global) Ltd.
Date: June 24, 2024 · CIK: 0001959726 · Accession: 0000000000-24-007108
AI Filing Summary & Sentiment
File numbers found in text: 333-273166
Letter
United States securities and exchange commission logo June 24, 2024 Houqi Zhang Chief Executive Officer Autozi Internet Technology (Global) Ltd. Building B09, Intelligence Park No. 26 Yongtaizhuang North Road Haidian District, Beijing, China Re:Autozi Internet Technology (Global) Ltd. Amendment No. 7 to Registration Statement on Form F-1 Filed June 20, 2024 File No. 333-273166 Dear Houqi Zhang: We have reviewed your amended 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. Unless we note otherwise, any references to prior comments are to comments in our June 18, 2024 letter. Amendment No. 7 to Registration Statement on Form F-1 filed June 20, 2024 Exhibit 99.2, page II-6 1.We note your response to prior comment 3 and reissue in part. Revise paragraph C(3) to state that the disclosure in the section "Taxation - People's Republic of China Taxation" constitutes your opinion. In this regard, your revised opinion states that the statements in this section are your opinion only "to the extent that such statements constitute statements of PRC Laws," however a "short-form" opinion should state that the disclosure in this section of the prospectus is the opinion of named counsel. Refer to Section III.B.2 of Staff Legal Bulletin No. 19. Also further revise the assumption in paragraph A(1) so that it excludes the "PRC Companies." In this regard, we note that the current language continues to assume the legal authority of persons that do not have such legal authority.
FirstName LastNameHouqi Zhang Comapany NameAutozi Internet Technology (Global) Ltd. June 24, 2024 Page 2 FirstName LastName Houqi Zhang Autozi Internet Technology (Global) Ltd. June 24, 2024 Page 2 Please contact Doug Jones at 202-551-3309 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. Please contact Rebekah Reed at 202-551-5332 or Lilyanna Peyser at 202-551-3222 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Yang Ge, Esq.
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United States securities and exchange commission logo
June 24, 2024
Houqi Zhang
Chief Executive Officer
Autozi Internet Technology (Global) Ltd.
Building B09, Intelligence Park No. 26
Yongtaizhuang North Road
Haidian District, Beijing, China
Re:Autozi Internet Technology (Global) Ltd.
Amendment No. 7 to Registration Statement on Form F-1
Filed June 20, 2024
File No. 333-273166
Dear Houqi Zhang:
We have reviewed your amended 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. Unless we note otherwise,
any references to prior comments are to comments in our June 18, 2024 letter.
Amendment No. 7 to Registration Statement on Form F-1 filed June 20, 2024
Exhibit 99.2, page II-6
1.We note your response to prior comment 3 and reissue in part. Revise paragraph C(3) to
state that the disclosure in the section "Taxation - People's Republic of China Taxation"
constitutes your opinion. In this regard, your revised opinion states that the statements in
this section are your opinion only "to the extent that such statements constitute statements
of PRC Laws," however a "short-form" opinion should state that the disclosure in this
section of the prospectus is the opinion of named counsel. Refer to Section III.B.2 of Staff
Legal Bulletin No. 19. Also further revise the assumption in paragraph A(1) so that it
excludes the "PRC Companies." In this regard, we note that the current language
continues to assume the legal authority of persons that do not have such legal authority.
FirstName LastNameHouqi Zhang
Comapany NameAutozi Internet Technology (Global) Ltd.
June 24, 2024 Page 2
FirstName LastName
Houqi Zhang
Autozi Internet Technology (Global) Ltd.
June 24, 2024
Page 2
Please contact Doug Jones at 202-551-3309 or Lyn Shenk at 202-551-3380 if you have
questions regarding comments on the financial statements and related matters. Please contact
Rebekah Reed at 202-551-5332 or Lilyanna Peyser at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Yang Ge, Esq.