United States securities and exchange commission logo
November 14, 2023
Peng Zhang
Vice President of Finance
Yunji Inc.
15/F, South Building
Hipark Phase 2, Xiaoshan District
Hangzhou, Zhejiang, 310000
People s Republic of China
Re: Yunji Inc.
Form 20-F for
Fiscal Year Ended December 31, 2022
Response Dated
September 27, 2023
File No. 001-38877
Dear Peng Zhang:
We have reviewed your September 27, 2023 response to our comment
letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 14, 2023
letter.
Response Dated September 27, 2023
Our Holding Company Structure and Contractual Arrangements with the
VIEs, page 4
1. We note your proposed
amended disclosure in response to comment 1, specifically that
"[t]hese risks could
... affect our ability to accept foreign investments or list on another
foreign stock exchange
outside of mainland China ... ." (Emphasis added). However,
please revise to
clarify that recent statements by China's government (not the legal and
operational risks) have
or may impact your ability to accept foreign investments or list on
a U.S. or other foreign
exchange.
Peng Zhang
FirstName
Yunji Inc. LastNamePeng Zhang
Comapany 14,
November NameYunji
2023 Inc.
November
Page 2 14, 2023 Page 2
FirstName LastName
Please contact Tatanisha Meadows at 202-551-3322 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Cara Wirth at 202-551-7127 or Dietrich King at 202-551-8071 with any
other questions.
Sincerely,
Division of
Corporation Finance
Office of Trade &
Services
cc: Shu Du, Esq.