**I. New Filings (3 Companies)**

Over the past week, 3 companies filed new listing applications: Hangzhou Jialin (Yangzhou Xiyue), Goertek Microelectronics, and Lemo IoT. Two companies applied for Hong Kong listings, while one applied for US listing.

**Hong Kong IPOs**

**1. Goertek Microelectronics** On July 21, 2025, Goertek Microelectronics submitted its prospectus to the Hong Kong Stock Exchange for the second time, seeking to list on the Main Board. Joint sponsors include China International Capital Corporation, CITIC Securities International, China Merchants Bank International, and UBS Group.

The company is a leading global provider of intelligent sensing and interaction solutions. In the first three quarters of 2024, it recorded revenue of RMB 3.266 billion, net profit of RMB 243 million, and gross margin of 19.4%.

The company is the sole subsidiary of Goertek Inc. (002241.SZ) operating microelectronics-related businesses. It previously applied for ChiNext listing in December 2021 but voluntarily withdrew the application. Parent company Goertek Inc. listed on Shenzhen Stock Exchange Main Board in May 2008 and currently has a market capitalization exceeding RMB 80 billion.

**2. Lemo IoT** On July 25, 2025, Lemo IoT submitted its prospectus to the Hong Kong Stock Exchange for the second time, seeking to list on the Main Board. Joint sponsors include CITIC Securities International and Shenwan Hongyuan Hong Kong.

The company is China's leading intelligent massage service provider. In 2024, it achieved revenue of nearly RMB 800 million (up 36% year-over-year), net profit of RMB 86 million, and gross margin exceeding 36%.

**US Listing Applicant**

**1. Hangzhou Jialin (Yangzhou Xiyue)** In January 2025, HZJL Cayman Limited, the holding company of Hangzhou Wukong Youxuan Supply Chain Management Co., Ltd., signed a merger agreement with SPAC company Rising Dragon Acquisition Corp (RDAC), aiming to go public on NASDAQ through a reverse SPAC merger.

The company's operating entity, Wukong Youxuan, is a solution provider committed to empowering local lifestyle businesses such as restaurants, coffee shops, beauty salons, convenience stores, and massage centers through innovative online social brand building, software applications, and supply chain services, providing one-stop solutions for overseas merchants.

**II. Filing Feedback Comments**

Over the past week, the International Department issued supplemental material requirements to 7 companies:

**Yangzhou Xiyue (Confidential to Public)**

**Question 1:** Please explain: (1) The compliance of your company's equity control structure setup, including specific situations regarding various entities involved in the establishment and return investment fulfilling regulatory procedures for foreign exchange management, overseas investment, foreign investment, and tax management, and explain compliance with "Regulations on Foreign Investors' Mergers and Acquisitions of Domestic Enterprises"; (2) Reasons and basis for Xiong Bin's spouse Hu Jiahui not being recognized as joint actual controller; (3) List the shareholding ratio correspondence between pre-flip shareholders and issuer-level shareholders in your company's structure reorganization, and explain any inconsistencies; (4) October 2024 Andaman Construction's capital increase in Hangzhou Wukong Youxuan Supply Chain Management Co., Ltd. and Hangzhou Jialin Information Technology Co., Ltd., and Andaman Construction's transfer of Hangzhou Wukong Youxuan Supply Chain Management Co., Ltd. equity pricing basis, payment status, and tax payment situation; (5) Fair pricing and compliance of May 2024 transfers: Hangzhou Jialin's RMB 0 transfer of 100% equity in Hangzhou Yanwei Supply Chain Management Co., Ltd., and Fan Chunhui's RMB 0 transfer of 27.9916% equity in Huzhou Jisheng Cultural Media Co., Ltd.

**Question 2:** Please explain: (1) Background of multiple related party loans provided by Hangzhou Jialin to Hangzhou Wukong, Hangzhou Zhulin Technology Co., Ltd., Huzhou Jisheng, and Hangzhou Yanwei, funding sources and repayment arrangements, whether necessary internal decision procedures were followed, whether interest transfer exists, and whether it will have major adverse effects on this issuance; (2) Domestic entity enterprises' registered capital payment status, and if insufficient payment exists, explain formation reasons and whether it will adversely affect normal business operations; (3) The 1.8198% equity freeze situation in Hangzhou Zhulin held by Shandong Jiman Supply Chain Management Co., Ltd., explain formation reasons and whether it constitutes substantial obstacles to this issuance and listing; (4) Further explain new shareholders' entry prices, pricing basis, and fairness in the recent year.

**Question 3:** Please explain: (1) Your subsidiary companies' business scope involves crop seed operations, market research, radio and television program production and performance brokerage. Please further self-examine whether company business involves prohibited or restricted foreign investment, and provide clear basis for compliance with "Special Administrative Measures for Foreign Investment Access (Negative List)"; (2) Explain whether your subsidiary companies' future intended businesses under "Value-added Telecommunications Business Operating License" involve prohibited or restricted foreign investment areas and continued compliance with the negative list.

**Question 4:** Please explain your company's specific transaction arrangements and relevant participants for achieving US issuance and listing through overseas special purpose acquisition companies, list your company's equity structure changes before and after merger, and provide post-merger listing equity structure diagram.

**Question 5:** Please explain: (1) Your company's developed and operated websites, APPs, mini-programs and other products, scale of collected and stored user information, data collection and usage, whether it involves providing personal user information to third parties, and personal information protection and data security arrangements before and after listing; (2) Further explain company's digital business situation, whether it involves collecting and storing personal user information held by customers, and isolation arrangements with customer-held personal user information.

**Hope Sea**

**Question 1:** From May to June 2025, your company acquired 100% equity in domestic operating entities through capital increase subscription of China Antrade equity (offshore shareholding entity of Shenzhen Huafuyang) and original shareholders' capital reduction exit. Please explain pricing basis, fairness, consideration payment and income tax payment for above capital increase and reduction, compliance with "Regulations on Foreign Investors' Mergers and Acquisitions of Domestic Enterprises," and conclusive opinions on legal compliance of foreign investment and tax management regulatory procedures, and explain conclusive opinions on legal compliance of major domestic operating entities' historical equity changes. Additionally, current filing materials have incorrect understanding of whether above capital reduction and increase processes apply to the regulations, please correct.

**Question 2:** Regarding cross-border fund arrangement compliance. Your company provides cross-border fund arrangement services for customers, including currency exchange business and trade structured settlement business. Please explain specific models of above cross-border fund arrangement services, pricing basis for customer charges, specific composition of cross-border fund arrangement net income, and explain whether above cross-border fund activities belong to current account or capital account and determination basis, whether corresponding foreign exchange business qualifications are needed, and compliance with foreign exchange management regulations.

**Question 3:** Please compare with "Regulatory Rule Application Guidelines - Overseas Issuance and Listing Category No. 2" to explain basic information after penetrating your company's shareholders upward.

**Question 4:** Please explain types, scale, sources, and usage of data information collected and stored during domestic operating entities' business development, whether it involves providing personal user information to third parties or overseas, and personal information protection and data security arrangements before and after listing.

**Question 5:** Please explain specific reasons your company should return subsidies to local government, latest progress of related litigation, and whether it constitutes substantial obstacles to this overseas issuance and listing.

**Kwintech Pharma**

**Question 1:** Regarding equity situation, please explain: (1) Suzhou Kwintech's July 2021 first equity transfer and September 2021 first registered capital reduction pricing basis, payment status and tax payment, whether transfer prices are fair, domestic regulatory procedures for foreign exchange, foreign investment management, and overseas investment compliance; (2) Please explain your company's control situation before and after issuance.

**Question 2:** Please explain whether your company and subsidiaries' business scope involves areas prohibited or restricted for foreign investment, and continued compliance with foreign investment access policies before and after this issuance.

**Question 3:** Please explain your company's option incentive plan share sources, whether unclear specific grantee situations exist, whether consultant participation exists, and if so, verify against regulatory guidelines.

**Basic Semiconductor**

**Question 1:** Please explain reasons for inconsistent controlling shareholder recognition results in filing materials and recognition standards, and provide clear conclusive opinions on controlling shareholder recognition.

**Question 2:** Please explain progress on state-owned shareholders' state-owned share identification processing.

**Question 3:** Please explain reasonableness of new shareholders' entry prices in recent 12 months, reasons for price differences, whether abnormal entry consideration or interest transfer exists, and provide conclusive opinions on your company's establishment and historical equity change compliance.

**Question 4:** Please explain equity incentive plan establishment background and price fairness, whether interest transfer exists.

**Question 5:** Please specifically explain listing plan, including issuance shares (including over-allotment), proportion of post-issuance total share capital, expected fundraising amount, and list equity structure changes before and after issuance and "full circulation."

**Question 6:** Please explain whether shares held by shareholders intending to participate in "full circulation" have pledge, freeze, or other right defects.

**ENN Energy Holdings**

**Question 1:** Please strictly compare with "Regulatory Rule Application Guidelines - No. 2" to supplement information on shareholders holding over 5% after penetration.

**Question 2:** Please strictly compare with Article 8 of "Interim Measures for Administration of Overseas Issuance and Listing of Securities by Domestic Enterprises" to supplement whether overseas issuance and listing prohibitive situations exist.

**Question 3:** Please supplement explanation of impact of controlling shareholder and persons acting in concert's pledged shares on this introduction listing.

**Question 4:** Please supplement reasons for reserved grants in your company's two restricted stock incentive plans.

**Question 5:** Please supplement foreign shareholding ratios of three controlling subsidiaries engaged in value-added telecommunications business (Yicheng Yijia, Haomai Qi, and Yuntu Cloud) before and after introduction listing, and continued compliance with foreign investment access policy requirements before and after listing.

**Question 6:** Please supplement whether shares held by shareholders intending to participate in "full circulation" have pledge, freeze, or other right defects.

**Meig Smart Technology**

**Question 1:** Please explain establishment of your company's predecessor Fanggejingmi and share capital and shareholder changes since establishment.

**Question 2:** Combined with actual controller's debt repayment capability, supplement whether controlling shareholder and actual controller equity pledge situations before and after this issuance completion may cause control changes, and whether it causes prohibitive situations under Article 8 of "Interim Measures for Administration of Overseas Issuance and Listing of Securities by Domestic Enterprises."

**Question 3:** Please explain subsidiary Nantong Zhongge's value-added telecommunications business development and licensing status, and continued compliance with "Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition)" requirements before and after issuance and listing.

**Unicore Communications**

**Question 1:** Please strictly compare with Article 8 of "Interim Measures for Administration of Overseas Issuance and Listing of Securities by Domestic Enterprises" to explain whether your company and domestic subsidiaries have overseas issuance and listing prohibitive situations.

**Question 2:** Regarding shareholder situation: (1) Your company has special shareholder rights arrangements, with only some shareholders agreeing to terminate special shareholder rights before listing. Please explain remaining shareholders' opinions and whether it constitutes substantial obstacles to this overseas issuance and listing; (2) Please explain progress on state-owned share identification for Gree Ventures, China Development Bank Capital, and China Electronics Port state-owned shareholders, and Gree Ventures' state asset management procedure progress for applying for "full circulation"; (3) Please explain whether shares held by shareholders intending to participate in "full circulation" have pledge, freeze, or other right defects.

**Question 3:** Regarding employee shareholding plans and equity incentives: (1) Your company has personnel still holding employee shareholding plan interests after departure. Please explain whether they currently hold interests according to plan charter or agreement provisions; (2) Please provide clear conclusive opinions on whether implemented equity incentives and employee shareholding plans involve interest transfer.

**Question 4:** Regarding business operations: (1) Your company and subsidiaries' business scope involves navigation terminals, mobile communication terminal products and supporting software development and sales, navigation, surveying, meteorological and marine instrument manufacturing and sales, aerospace terminal manufacturing, navigation equipment R&D, satellite navigation services, satellite remote sensing application system integration, satellite remote sensing data processing, geographic remote sensing information services, geological disaster treatment engineering construction, surveying services, and hydrological services. Please explain above business development, whether necessary qualifications obtained, whether third-party cooperation exists and partner names (whether partners hold qualifications), cooperation methods, whether it involves "Special Administrative Measures for Foreign Investment Access (Negative List) (2024 Edition)" restricted or prohibited areas, and continued compliance with foreign investment access requirements after issuance and "full circulation"; (2) Your company's main business revenue comes from selling integrated chips and module products. Please explain contract terms with major suppliers and specific distribution cooperation models, and explain differences and connections between integrated chip business and GNSS chip business.

**Question 5:** Please supplement detailed situations and termination reasons for two previous A-share listing guidance filings, whether plans to continue A-share listing and specific arrangements exist, and whether situations with major impact on this issuance and listing exist.