Response:
In response to the Staffs comment, the Company has revised the disclosure on pages 39 and 40 of the Revised Draft Registration Statement.
Risks Relation to Our ADSs and this Offering
As a company incorporated in the Cayman Islands . . ., page 53
2. | You disclose that [you] have relied on and intend to continue to rely on some of these [corporate governance] exemptions. Please identify the specific exemptions upon which you have relied and intend to continue to rely. |
Response:
In response to the Staffs comment, the Company has revised the disclosure on page 53 of the Revised Draft Registration Statement.
Overview of Chinas Private Primary and Secondary Education Market
Introduction of Chinas private primary and secondary education market, page 95
3. | We note your response to comment 14, and your amended disclosure on page 95 that From 2014 to 2018 the total number of students enrolled in private primary and secondary schools in China increased from 14.0 million to 18.5 million, and the total revenue of private primary and secondary education market increased from RMB95.5 billion to RMB201.0 billion, due to the growth of age group of 7 to 12 years old and policy support from the government. Specifically, student enrollment of primary schools, middle schools and high schools grew from 6.7 million to 8.9 million, from 4.9 million to 6.4 million and from 2.4 million to 3.3 million, respectively. Please disclose the total number of students enrolled in private primary and secondary schools and total revenue of private primary and secondary education market for 2019, and clarify whether these measures increased for 2019 as well. Please make conforming changes to your filing, including, but not limited to, where you discuss Average annual tuition fee in Zhejiang Province, and Average annual salaries and benefits of the teachers in Zhejiang Province. Alternatively, please tell us why you are unable to provide data for 2019. |
Response:
In response to the Staffs comment, the Company has revised the disclosure on pages 92 and 94 to 105 of the Revised Draft Registration Statement.
Should you have any questions about the responses contained herein, please contact me by telephone at (852) 2840 5026 (office) or via email at stephanie.tang@hoganlovells.com. Questions relating to accounting and auditing matters of the Company may also be directed to Theodore Deng, partner at PricewaterhouseCoopers Zhong Tian LLP (PwC), by telephone at (86) 21 2323 2567 or via email at theodore.deng@cn.pwc.com. PwC is the independent registered public accounting firm of the Company.
Sincerely yours, |
/s/ Stephanie Tang |
Stephanie Tang |
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CC: | Biao Wei, director and chief executive officer, Lixiang Education Holding Co., Ltd. Theodore Deng, Partner, PricewaterhouseCoopers Zhong Tian LLP Galleon Lin, Partner, PricewaterhouseCoopers Zhong Tian LLP Dan Ouyang, Esq., Partner, Wilson Sonsini Goodrich & Rosati, Professional Corporation |
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