JUNENG Technology plans to list on the US stock market, and the China Securities Regulatory Commission requires supplementary explanations on the compliance of the company's equity control structure

According to the Zhitong Finance APP, on July 26, the China Securities Regulatory Commission (CSRC) announced the public disclosure of supplementary material requirements for overseas issuance and listing (July 18, 2025 - July 24, 2025). The CSRC requested that JuNeng Technology provide additional explanations regarding the compliance of the company's equity control structure, including but not limited to the specific circumstances of relevant parties involved in the establishment and reverse mergers fulfilling foreign exchange management, overseas investment, foreign investment, tax management, and other regulatory procedures, and further clarify whether it complies with the "Regulations on Foreign Investors Merging Domestic Enterprises," among others. On June 27, the company submitted its initial public offering (IPO) application to the U.S. Securities and Exchange Commission, aiming to raise up to $9 million. Specifically, the CSRC requested the company to supplement the following matters and asked lawyers to verify and provide clear legal opinions: Please explain: (1) The compliance of the company's equity control structure, including but not limited to the specific circumstances of relevant parties involved in the establishment and reverse mergers fulfilling foreign exchange management, overseas investment, foreign investment, tax management, and other regulatory procedures, and further clarify whether it complies with the "Regulations on Foreign Investors Merging Domestic Enterprises." (2) List and explain the corresponding shareholding ratios of pre-restructured shareholders and shareholders at the issuer level, and clarify whether there are any inconsistencies in shareholding ratios. (3) The payment situation of newly added shareholders in the past year, the basis for price determination and fairness, and whether there are any situations of benefit transfer. (4) List and explain the prices and basis for the acquisition of Beijing Minghe's equity by Beijing HaoyuQin in November 2024 and the acquisition of Chongqing HaoyuQin's equity by Beijing Minghe in January 2025, as well as the payment situation and tax payment situation. Please explain: (1) There are situations where Beijing Minghe and Chongqing HaoyuQin have not fully paid their registered capital; please explain the reasons and whether it will adversely affect the normal business operations of domestic operating entities. (2) The business scope of the company's domestic entities includes advertising publishing and performance brokerage; please explain the status of related business operations. Please explain: The company's business involves real-time data analysis and user behavior analysis. Please clarify whether the company is involved in collecting and storing user information, the scale of data, data collection and usage situations, whether it involves providing personal user information to third parties, and the arrangements or measures for personal information protection and data security before and after the listing. According to the prospectus, JuNeng Technology is a company that provides digital marketing solutions for Chinese advertisers. In this IPO, the company plans to issue 2 million shares, with an offering price range of $4 to $5, raising $9 million. Based on the midpoint of the proposed range, JuNeng Technology's market value will reach $144 million. JuNeng Technology provides digital marketing solutions in China through its operating entity Chongqing HaoyuQin Cultural Media Co., Ltd., serving clients across various industries. JuNeng Technology utilizes its proprietary "Lucky Short Video Intelligent Data Analysis System" to assess the efficiency of different visual elements in short video advertisements. The company has established partnerships with authorized third-party agents of leading media platforms such as Tencent and ByteDance, and places advertisements for clients through these agents