Kuneng Technology plans to list on the US stock market. The China Securities Regulatory Commission requires additional details on the compliance of the company's equity control structure.

On July 26th, the China Securities Regulatory Commission announced the supplementary materials requirements for overseas issuance and listing filing disclosure (July 18, 2025 to July 24, 2025). The China Securities Regulatory Commission requested JuNeng Technology to provide further explanation on the compliance of the company's equity control structure, including but not limited to the specifics of the foreign exchange management, overseas investment, foreign investment, tax management, and other regulatory procedures performed by various related parties involved in cross-border mergers and acquisitions, and further clarify whether it complies with the regulations on the acquisition of domestic enterprises by foreign investors. On June 27th, the company submitted an initial public offering application to the US Securities and Exchange Commission, aiming to raise up to $9 million. Specifically, the China Securities Regulatory Commission requested the company to supplement the following matters and asked lawyers to verify and provide clear legal opinions: 1. Please explain: (1) the compliance of the company's equity control structure establishment, including but not limited to the specifics of the foreign exchange management, overseas investment, foreign investment, tax management, and other regulatory procedures performed by various related parties involved in cross-border mergers and acquisitions, and further clarify whether it complies with the regulations on the acquisition of domestic enterprises by foreign investors. (2) List the ownership structure of the issuer's restructuring of equity before and after the foreign mergers and acquisitions at both the shareholder and issuer levels, and explain whether there is any inconsistency in shareholding percentages. (3) Payment information of new shareholders in the past year, basis for price determination, and fairness, and whether there is any related party transaction. (4) List the prices and basis for determination of Beijing Haoyu Qin's acquisition of Beijing Mingge's equity in November 2024, and Beijing Mingge's acquisition of Chongqing Haoyu Qin's equity in January 2025, payment information, and tax payment status. 2. Please explain: (1) The situation where Beijing Mingge and Chongqing Haoyu Qin have not fully paid-up registered capital, please explain the reasons for this and whether it will adversely affect the normal business operations of domestic operating entities. (2) The company's domestic entity's business scope includes advertising publishing and performance brokerage, please explain the situation of relevant business operations. 3. Please explain: The company's business involves real-time data analysis and user behavior analysis. Please explain whether the company collects and stores user information, the scale of data, data collection and usage, whether it provides personal user information to third parties, arrangements or measures for personal information protection and data security before and after listing. According to the prospectus, JuNeng Technology is a company that provides digital marketing solutions for Chinese advertisers. In this IPO, the company plans to issue 2 million shares of stock with an offering price range of $4 to $5 per share, raising $9 million. Based on the mid-point price in the proposed range, JuNeng Technology's market value will reach $144 million. JuNeng Technology provides digital marketing solutions in China through its operational entity, Chongqing Haoyu Qin Cultural Media Co., Ltd., serving clients from various industries. JuNeng Technology uses its proprietary "Lucky Short Video Intelligent Data Analysis System" to assess the effectiveness of different visual elements in short video advertisements. The company has established partnerships with authorized third-party agents of leading media platforms such as Tencent and ByteDance, and serves clients through these agents to place advertisements.