United States securities and exchange commission logo
October 26, 2022
Raymond Ming Hui Lin
Chief Executive Officer
CLPS Incorporation
c/o Unit 1102, 11th Floor, Millennium City III
370 Kwun Tong Road, Kwun Tong, Kowloon
Hong Kong SAR
Re: CLPS Incorporation
Amendment No. 1 to
Registration Statement on Form F-3
Filed October 12,
2022
File No. 333-266951
Dear Raymond Ming Hui Lin:
We have reviewed your amended 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.
Unless we note
otherwise, our references to prior comments are to comments in our
September 13, 2022 letter.
Amendment No. 1 to F-3
Cover Page
1. Please disclose on the
cover page that your auditor, Ernst & Yong Hua Ming LLP,
is subject to the
determinations announced by the PCAOB on December 16,
2021. Disclose whether
and how the Holding Foreign Companies Accountable Act and
related regulations
will affect your company. Discuss the Statement of Protocol and that
trading in your
securities may be prohibited under the Holding Foreign Companies
Accountable Act if the
PCAOB determines that it cannot inspect or investigate completely
your auditor, and that
as a result an exchange may determine to delist your securities.
Raymond Ming Hui Lin
CLPS Incorporation
October 26, 2022
Page 2
2. We note your response to prior comment 2 and we reissue it in part.
Please disclose on
the cover page the legal and operational risks associated with being
based in or having the
majority of your operations in China. Also, include the information you
provide in your
response to prior comment 2 on the prospectus cover page.
3. We note your response to prior comment 3 regarding how cash is
transferred through
your organization. Please include the information from your response on
the cover page
and in the prospectus summary.
Summary, page 4
4. We note your response to prior comment 4 regarding permissions or
approvals. Please
include the information in the prospectus summary.
Please contact Matthew Crispino, Staff Attorney, at (202) 551-3456 or
Jan Woo,
Legal Branch Chief, at (202) 551-3453 with any questions.
Sincerely,
FirstName LastNameRaymond Ming Hui Lin
Division of
Corporation Finance
Comapany NameCLPS Incorporation
Office of Technology
October 26, 2022 Page 2
cc: James Zhang
FirstName LastName