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SEC Comment Letter 0000000000-24-003941 to Jinxin Technology Holding Co (NAMI) (CIK 0001967631) (NAMI)

Jinxin Technology Holding Co (NAMI) (CIK 0001967631)
Date: April 11, 2024 · CIK: 0001967631 · Accession: 0000000000-24-003941

Revenue Recognition Financial Reporting Regulatory Compliance

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File numbers found in text: 333-273884

Date
April 11, 2024
Author
Jun Jiang
Form
UPLOAD
Company
Jinxin Technology Holding Co (NAMI) (CIK 0001967631)

Letter

United States securities and exchange commission logo April 11, 2024 Jun Jiang Chief Operating Officer Jinxin Technology Holding Co Floor 8, Building D, Shengyin Building Shengxia Road 666 Pudong District, Shanghai 201203 People’s Republic of China Re:Jinxin Technology Holding Co Amendment No. 1 to Registration Statement on Form F-1 Filed April 2, 2024 File No. 333-273884 Dear Jun Jiang: 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. Amendment No. 1 to Registration Statement on Form F-1 Notes to Consolidated Financial Statements Note 2. Summary of Significant Accounting Policies Revenue recognition Revenue from sales of digital educational hardware devices, page F-19 1.Please revise the first sentence to clarify its meaning. Please clarify whether the company or the hardware distributor who purchases your digital education hardware device installs the digital educational content to end users.

FirstName LastNameJun Jiang Comapany NameJinxin Technology Holding Co April 11, 2024 Page 2 FirstName LastName Jun Jiang Jinxin Technology Holding Co April 11, 2024 Page 2 Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Steve Lin

Show Raw Text
United States securities and exchange commission logo
April 11, 2024
Jun Jiang
Chief Operating Officer
Jinxin Technology Holding Co
Floor 8, Building D, Shengyin Building
Shengxia Road 666
Pudong District, Shanghai 201203
People’s Republic of China
Re:Jinxin Technology Holding Co
Amendment No. 1 to Registration Statement on Form F-1
Filed April 2, 2024
File No. 333-273884
Dear Jun Jiang:
            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.
Amendment No. 1 to Registration Statement on Form F-1
Notes to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue recognition
Revenue from sales of digital educational hardware devices, page F-19
1.Please revise the first sentence to clarify its meaning. Please clarify whether the company
or the hardware distributor who purchases your digital education hardware device installs
the digital educational content to end users.

 FirstName LastNameJun Jiang
 Comapany NameJinxin Technology Holding Co
 April 11, 2024 Page 2
 FirstName LastName
Jun Jiang
Jinxin Technology Holding Co
April 11, 2024
Page 2
            Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Steve Lin