United States securities and exchange commission logo
February 21, 2023
Feng Lin
Chief Financial Officer
Uxin Ltd
1&3/F, No. 12 Beitucheng East Road
Chaoyang District, Beijing 100029
People s Republic of China
Re: Uxin Limited
Form 20-F for the
Year Ended March 31, 2022
Correspondence
Filed January 9, 2023
File No. 001-38527
Dear Feng Lin:
We have reviewed your January 9, 2023 response to our comment
letter 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 these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
December 27, 2022 letter.
Correspondence Filed January 9, 2023
Item 3. Key Information
Permissions Required from the PRC Authorities, page 4
1. We note your response
to comment 3. Please clarify whether you disclose each permission
or approval that you
and your subsidiaries are required to obtain from Chinese authorities
to operate your
business and to offer the securities being registered to foreign investors,
and if not, please
disclose each required approval.
Feng Lin
FirstName
Uxin Ltd LastNameFeng Lin
Comapany21,
February NameUxin
2023 Ltd
February
Page 2 21, 2023 Page 2
FirstName LastName
Risk Factors
You may experience difficulties in effecting service of legal process,
enforcing foreign
judgments or bringing actions..., page 28
2. We note your response to comment 4. Please further revise to identify
the directors
and senior executive officers whom you state reside within mainland
China and Hong
Kong for a significant portion of the time.
Please contact Jennie Beysolow at 202-551-8108 or Taylor Beech at
202-551-4515 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Shu Du, Esq.