Correspondence 0001213900-26-011018 from Zhibao Technology Inc. (ZBAO)
Zhibao Technology Inc.
Date: Feb. 2, 2026 · CIK: 0001966750 · Accession: 0001213900-26-011018
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Reasoning
File numbers found in text: 333-290132
Letter
VIA EDGAR Division of Corporation Finance Office of Finance Attention: Susan Block Re: Zhibao Technology Inc. Registration Statement on Form F-1 Filed September 9, 2025 File No. 333-290132
Dear Susan and Christian:
Zhibao Technology Inc. (the " Company ," " we ," " our " or " us ") hereby transmits its response to the oral comment communicated by the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") on January 21, 2026, regarding the Company's Registration Statement on Form F-1 (the " Registration Statement ") initially filed with the Commission on September 9, 2025.
In response to the Staff's comment, we have revised the disclosures in Incorporation of Certain Information by Reference on page 98 of the Registration Statement.
We thank the Staff in advance for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our legal counsel, Lijia Sanchez, Esq., of Ellenoff Grossman & Schole LLP, at lsanchez@egsllp.com or by telephone at (212) 370-1300.
Sincerely,
By:
/s/ Botao Ma
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CORRESP 1 filename1.htm Zhibao Technology Inc. Floor 3, Building 6, Wuxing Road, Lane 727 Pudong New Area, Shanghai 201204 VIA EDGAR February 2, 2026 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Susan Block Christian Windsor Re: Zhibao Technology Inc. Registration Statement on Form F-1 Filed September 9, 2025 File No. 333-290132 Dear Susan and Christian: Zhibao Technology Inc. (the " Company ," " we ," " our " or " us ") hereby transmits its response to the oral comment communicated by the staff (the " Staff ") of the U.S. Securities and Exchange Commission (the " Commission ") on January 21, 2026, regarding the Company's Registration Statement on Form F-1 (the " Registration Statement ") initially filed with the Commission on September 9, 2025. In response to the Staff's comment, we have revised the disclosures in Incorporation of Certain Information by Reference on page 98 of the Registration Statement. We thank the Staff in advance for its consideration of the foregoing. Should you have any questions, please do not hesitate to contact our legal counsel, Lijia Sanchez, Esq., of Ellenoff Grossman & Schole LLP, at lsanchez@egsllp.com or by telephone at (212) 370-1300. Sincerely, By: /s/ Botao Ma Name: Botao Ma Title: Chief Executive Officer cc: Lijia Sanchez, Esq.