SEC Comment Letter 0000000000-23-013662 to Youxin Technology Ltd (YAAS)
Youxin Technology Ltd
Date: Dec. 14, 2023 · CIK: 0001964946 · Accession: 0000000000-23-013662
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-274404
Letter
United States securities and exchange commission logo December 14, 2023 Shaozhang Lin Chief Executive Officer Youxin Technology Ltd Room 802, 803, No. 13 Hai’an Road Tianhe District, Guangzhou Guangdong Province, People's Republic of China Re:Youxin Technology Ltd Amendment No. 2 to Registration Statement on Form F-1 Filed December 8, 2023 File No. 333-274404 Dear Shaozhang Lin: 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 28, 2023 letter. Amendment No. 2 to Registration Statement on Form F-1 Factors Affecting Our Performance, page 54 1.We note from your response to prior comment 3 that the customer renewal rate calculation excludes customers with existing contracts whose terms do not expire during the period. It appears from your disclosures on page F-13 that your contract terms are typically one year. Therefore, please clarify for us which customers are not subject to renewal such that they would be excluded from this calculation. To the extent contract terms extend beyond one year, either initially or upon renewal, revise to disclose as such.
FirstName LastNameShaozhang Lin Comapany NameYouxin Technology Ltd December 14, 2023 Page 2 FirstName LastName Shaozhang Lin Youxin Technology Ltd December 14, 2023 Page 2 General 2.We note your response to prior comment 5; however, we continue to note changes you made to your disclosure appearing on the cover page, Summary and Risk Factor sections relating to legal and operational risks associated with operating in China and PRC regulations and it continues to be unclear to us that there have been changes in the regulatory environment in the PRC since the amendment that was filed on July 17, 2023 warranting revised disclosure to mitigate the challenges you face and related disclosures. For example, on the cover page, you no longer disclose that the interpretation and implementation of the New Administrative Rules Regarding Overseas Listings “involve uncertainties.” Please tell us the reasons for these changes or revise your disclosure throughout the registration statement as applicable. Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you have questions regarding comments on the financial statements and related matters. Please contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-3334 with any other questions. Sincerely, Division of Corporation Finance Office of Technology cc: Anthony Basch
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United States securities and exchange commission logo
December 14, 2023
Shaozhang Lin
Chief Executive Officer
Youxin Technology Ltd
Room 802, 803, No. 13 Hai’an Road
Tianhe District, Guangzhou
Guangdong Province, People's Republic of China
Re:Youxin Technology Ltd
Amendment No. 2 to Registration Statement on Form F-1
Filed December 8, 2023
File No. 333-274404
Dear Shaozhang Lin:
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 28, 2023 letter.
Amendment No. 2 to Registration Statement on Form F-1
Factors Affecting Our Performance, page 54
1.We note from your response to prior comment 3 that the customer renewal rate calculation
excludes customers with existing contracts whose terms do not expire during the period. It
appears from your disclosures on page F-13 that your contract terms are typically one
year. Therefore, please clarify for us which customers are not subject to renewal such that
they would be excluded from this calculation. To the extent contract terms extend beyond
one year, either initially or upon renewal, revise to disclose as such.
FirstName LastNameShaozhang Lin
Comapany NameYouxin Technology Ltd
December 14, 2023 Page 2
FirstName LastName
Shaozhang Lin
Youxin Technology Ltd
December 14, 2023
Page 2
General
2.We note your response to prior comment 5; however, we continue to note changes you
made to your disclosure appearing on the cover page, Summary and Risk Factor sections
relating to legal and operational risks associated with operating in China and PRC
regulations and it continues to be unclear to us that there have been changes in the
regulatory environment in the PRC since the amendment that was filed on July 17, 2023
warranting revised disclosure to mitigate the challenges you face and related disclosures.
For example, on the cover page, you no longer disclose that the interpretation and
implementation of the New Administrative Rules Regarding Overseas Listings “involve
uncertainties.” Please tell us the reasons for these changes or revise your disclosure
throughout the registration statement as applicable.
Please contact Chen Chen at 202-551-7351 or Kathleen Collins at 202-551-3499 if you
have questions regarding comments on the financial statements and related matters. Please
contact Alexandra Barone at 202-551-8816 or Matthew Derby at 202-551-3334 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Anthony Basch