United States securities and exchange commission logo
June 3, 2021
Kerry Xuefeng Chen
Chief Executive Officer
AiHuiShou International Co. Ltd.
12th Floor, No. 6 Building, 433 Songhu Road
Shanghai, People s Republic of China
Re: AiHuiShou
International Co. Ltd.
Registration
Statement on Form F-1
Filed May 28, 2021
File No. 333-256615
Dear Mr. Chen:
We have reviewed your registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so
we may better
understand your disclosure.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1 filed May 28, 2021
Business
Our Strategic Partners
Other Internet Platforms, page 167
1. Please revise the
description of your business cooperation framework agreement with
Kuaishou to disclose
that the term of the initial agreement is 36 months.
Related Party Transactions, page 206
2. We note that you have
included information in your Transactions with Related Parties
section for
transactions for the three months ended March 31, 2021. Please update this
disclosure through the
date of this document. See Item 7.B of Form 20-F.
Kerry Xuefeng Chen
AiHuiShou International Co. Ltd.
June 3, 2021
Page 2
Description of Share Capital, page 209
3. Please revise your Description of Share Capital section to reflect the
exclusive forum
provision included in Exhibit 3.2. Additionally, please revise your
Description of
American Depositary Shares to state whether the exclusive forum provision
applies to
actions arising under the Securities Act and Exchange Act.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Cara Wirth at (202) 551-7127 or Dietrich King at (202)
551-8071 with any
questions.
Sincerely,
FirstName LastNameKerry Xuefeng Chen
Division of
Corporation Finance
Comapany NameAiHuiShou International Co. Ltd.
Office of Trade &
Services
June 3, 2021 Page 2
cc: Z. Julie Gao
FirstName LastName