Correspondence 0001493152-24-007439 from Youxin Technology Ltd (YAAS)
Youxin Technology Ltd
Date: Feb. 21, 2024 · CIK: 0001964946 · Accession: 0001493152-24-007439
AI Filing Summary & Sentiment
Reasoning
Referenced dates: February 12, 2024
Letter
Office of Technology Division of Corporate Finance Re: Youxin Technology Ltd Amendment No. 5 to Registration Statement on Form F-1 Filed February 2, 2024 CIK No. 0001964946
Dear Ms. Barone, Mr. Spirgel, Ms. Collins, and Ms. Chen:
This letter is in response to the letter dated February 12, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed to Youxin Technology Ltd (the “Company,” “we,” and “our”). For ease of reference, we have recited the Staff’s comments in this response and numbered them accordingly.
Amendment No. 5 to Registration Statement on Form F-1
Note 3. Summary of Significant Accounting Policies
bb. Revision of previously issued Consolidated Statements of Balance Sheets, Operations and Comprehensive Loss..., page F-17
1. We note your response to prior comment 2, however, it remains unclear how you determined that the qualitative factors overcome the quantitative significance of the error. In this regard, while you refer to the dollar impact of this error, on a percentage basis, this error impacted earnings per share by approximately 15% as a percentage of the as corrected balance. Please explain or as previously requested, revise to label the appropriate columns of the financial statements as restated and have your auditor revise its report to reference the restatement consistent with paragraph 18e of PCAOB Accounting Standard 3101.
Response: In response to Staff’s comment, the Company has restated its previously reported consolidated balance sheets on page F-3, consolidated statements of operations and comprehensive loss on page F-4, and consolidated statements of changes in shareholders’ deficit on page F-5, as well as the disclosures for Note 12 - basic and diluted loss per share on page F-23 and Note 19 - financial information of the parent company on page F-28, and added disclosures for the details restatement on Note 17 – RESTATEMENT OF CONSOLIDATED FINANCIAL STATEMENTS.
Should you have any questions with respect to the above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.
Sincerely,
/s/ Shaozhang Lin
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Youxin Technology Ltd
Room 802, 803
No. 13 Hai’an Road, Tianhe District, Guangzhou,
Guangdong Province ♦ People’s Republic of China
February 21, 2024
Ms. Alexandra Barone
Mr. Larry Spirgel
Ms. Kathleen Collins
Ms. Chen Chen
Office of Technology
Division of Corporate Finance
U.S. Securities and Exchange Commission
Mail Stop 4631
100 F Street, N.E.
Washington, D.C. 20549-4631
Re:
Youxin Technology Ltd
Amendment No. 5 to Registration
Statement on Form F-1
Filed February 2, 2024
CIK No. 0001964946
Dear Ms. Barone, Mr. Spirgel, Ms. Collins, and Ms.
Chen:
This letter is in response to the letter dated February
12, 2024, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) addressed
to Youxin Technology Ltd (the “Company,” “we,” and “our”). For ease of reference, we have recited
the Staff’s comments in this response and numbered them accordingly.
Amendment No. 5 to Registration Statement on
Form F-1
Note 3. Summary of Significant Accounting Policies
bb. Revision of previously issued Consolidated
Statements of Balance Sheets, Operations and Comprehensive Loss..., page F-17
1.
We note your response to prior comment 2, however, it remains unclear how you determined that the qualitative factors overcome the quantitative significance of the error. In this regard, while you refer to the dollar impact of this error, on a percentage basis, this error impacted earnings per share by approximately 15% as a percentage of the as corrected balance. Please explain or as previously requested, revise to label the appropriate columns of the financial statements as restated and have your auditor revise its report to reference the restatement consistent with paragraph 18e of PCAOB Accounting Standard 3101.
Response: In response to Staff’s comment, the
Company has restated its previously reported consolidated balance sheets on page F-3, consolidated statements of operations and comprehensive
loss on page F-4, and consolidated statements of changes in shareholders’ deficit on page F-5, as well as the disclosures for Note
12 - basic and diluted loss per share on page F-23 and Note 19 - financial information of the parent company on page F-28, and added disclosures
for the details restatement on Note 17 – RESTATEMENT OF CONSOLIDATED FINANCIAL STATEMENTS.
Should you have any questions with respect to the
above responses, please contact me or our U.S. legal counsel, Anthony W. Basch.
Sincerely,
/s/ Shaozhang Lin
Shaozhang Lin