SEC Comment Letter 0000000000-23-012844 to Fly-E Group, Inc. (FLYE)
Fly-E Group, Inc.
Date: Nov. 27, 2023 · CIK: 0001975940 · Accession: 0000000000-23-012844
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United States securities and exchange commission logo
November 27, 2023
Steven Guo
Chief Financial Officer
Fly-E Group, Inc.
136-40 39th Avenue
Flushing, NY 11354
Re:Fly-E Group, Inc.
Amendment No. 1 to
Draft Registration Statement on Form S-1
Submitted November 13, 2023
CIK No. 0001975940
Dear Steven Guo:
We have reviewed your amended draft registration statement and have the following
comment(s).
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 1 to Registration Statement on Form S-1
Risk Factors
Improper activities by third parties, exploitation of encryption technology, new data-hacking
tools ... , page 16
1.We note your response to comment 4 and reissue. Please describe the cybersecurity risks
faced by the Company in connection with the Company's supply chain/suppliers/service
providers.
Capitalization, page 25
2.We note your response to comment 6. Please revise the total capitalization to include both
total debt and total stockholders' equity. Also please double underline the cash and cash
equivalents amounts to highlight that these amounts are not included in total
FirstName LastNameSteven Guo
Comapany NameFly-E Group, Inc.
November 27, 2023 Page 2
FirstName LastName
Steven Guo
Fly-E Group, Inc.
November 27, 2023
Page 2
capitalization.
Please contact Stephany Yang at 202-551-3167 or Jean Yu at 202-551-3305 if you have
questions regarding comments on the financial statements and related matters. Please contact
Alex King at 202-551-8631 or Evan Ewing at 202-551-5920 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Richard Aftanas