United States securities and exchange commission logo
September 19, 2023
Yuanjun Ye
Chief Financial Officer
LightInTheBox Holding Co., Ltd.
51 Tai Seng Avenue
#05-02B/C, Pixel Red
Singapore 533941
Re: LightInTheBox
Holding Co., Ltd.
Form 20-F for
Fiscal Year Ended December 31, 2022
File No. 001-35942
Dear Yuanjun Ye:
We have limited our review of your filing to the submission
and/or disclosures as
required by Item 16I of Form 20-F and have the following comment. In our
comment, we may
ask you to provide us with information so we may better understand your
disclosure.
Please respond to this comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond.
After reviewing your
response to this comment, we may have additional comments.
Form 20-F for Fiscal Year Ended December 31, 2022
Disclosure Regarding Foreign Jurisdictions that Prevent Inspections,
page 83
1. We note that during
your fiscal year 2022 you were identified by the Commission
pursuant to Section
104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C.
7214(i)(2)(A)) as
having retained, for the preparation of the audit report on your financial
statements included in
the Form 20-F, a registered public accounting firm that has a
branch or office that
is located in a foreign jurisdiction and that the Public Company
Accounting Oversight
Board had determined it is unable to inspect or investigate
completely because of a
position taken by an authority in the foreign jurisdiction. Please
provide the
documentation required by Item 16I(a) of Form 20-F or tell us why you are
not required to do so.
Additionally, please amend your Form 20-F to provide the
disclosures required
under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the
Holding Foreign
Companies Accountable Act and the Consolidated Appropriations Act,
2023, available on our
website at https://www.sec.gov/corpfin/announcement/statement-
hfcaa-040623.
Yuanjun Ye
LightInTheBox Holding Co., Ltd.
September 19, 2023
Page 2
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at
202-551-3377 with
any questions.
Sincerely,
FirstName LastNameYuanjun Ye
Division of
Corporation Finance
Comapany NameLightInTheBox Holding Co., Ltd.
Disclosure Review
Program
September 19, 2023 Page 2
cc: Yu Wang
FirstName LastName