United States securities and exchange commission logo
October 12, 2023
Shan-Nen Bong
Chief Financial Officer
Aurora Mobile Limited
14/F, China Certification and Inspection Building
No. 6, Keji South 12th Road , Nanshan District
Shenzhen, Guangdong 518057
People s Republic of China
Re: Aurora Mobile
Limited
Form 20-F filed on
April 18, 2023
Response letter
dated September 20, 2023
File No. 001-38587
Dear Shan-Nen Bong:
We have reviewed your September 20, 2023 response to our comment
letter.. In order to
help us more fully evaluate your responses to prior comments 2 and 3
regarding the Investment
Company Act of 1940 (the Investment Company Act ), we have the
following comments:
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 July 21, 2023 letter.
Response letter dated September 20, 2023
Item 3. Key Information, page 3
1. In response to prior
comment 2, you stated As of June 30, 2023, the Company and its
subsidiaries and VIE
had 429 employees, none of whom are actively engaged in managing
the Company s and its
subsidiaries and VIE s investments on a full-time basis. Please
clarify whether the
Company, its subsidiaries or the VIE have any employees, and the
number of employees,
who manage the Company s and its subsidiaries and VIE s
investments on a
part-time basis.
2. In response to prior
comment 3, we note that you provided a table for the Company,
listing Value of
subsidiary at 127, 422, 195 USD. We also note that the organization
Shan-Nen Bong
Aurora Mobile Limited
October 12, 2023
Page 2
chart you provided in the response letter from July 21, 2023 listed
two subsidiaries: 1)
Meta Reality Limited and 2) UA Mobile Limited. Please clarify whether
the value of
subsidiary notation includes both such entities. If not, please
update the table to reflect
the value of both of the Company s subsidiaries.
3. In response to prior comment 3, pertaining to the table you provide
for JPush
InformationConsultation (Shenzhen) Co., Ltd. ( JPush ) we have the
following
comments:
Please explain how the VIE is reflected on the JPush table.
The table refers to trade receivables, prepayments,
other receivables, and a
right-of-use asset. As requested previously, please provide
a detailed factual
description of each of these items and the legal basis for your
apparent position that
such items are not investment securities.
4. The staff reserves the right to ask additional questions about the
tables provided for
various other entities, including, in particular, your proposed
treatment of various assets as
non-investment securities. In the meantime, the staff notes that, in
the response to prior
comment 3, you state in note 5 that: Intangible assets represent
computer software,
systems and technology, brand and customer relationship acquired in a
business
combination. Please provide specific facts and details regarding
the nature of the
intangible assets and the business combination mentioned.
Please contact Becky Chow at 202-551-6524 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters.
FirstName LastNameShan-Nen Bong Sincerely,
Comapany NameAurora Mobile Limited
Division of
Corporation Finance
October 12, 2023 Page 2 Office of
Technology
FirstName LastName