Ser chain technology (Zero Degree Digital Group) intends to list on the US stock market. The China Securities Regulatory Commission requires further explanation of the main business content and other situations.
It is required that Zhenglian Technology (Zero-degree Digital Group) (transform from private to public) provide supplementary explanations on their main business activities, including descriptions of the specific functions and application scenarios of the company's main products, taking into account the five largest clients and their business types during the reporting period of each year.
On August 1st, the China Securities Regulatory Commission (CSRC) disclosed the "Supplementary Materials Requirements for Overseas Issuance and Listing Filing (July 25, 2025 - July 31, 2025)", and the International Department of the CSRC issued supplementary material requirements to 9 companies. Among them, Zhenglian Technology (Zerolimit Digital Group) (confidentially transferred to public) was required to supplement explanations of its main business operations, including specific functionalities and application scenarios of its main products, combined with the top five customers and their business types during the reporting period. It is reported that Zhenglian Technology (Shenzhen) Co., Ltd. plans to list on Nasdaq, with plans to issue 2 million ordinary shares at a price of $4 per share, raising $8 million and an expected market value of $200 million.
The CSRC asked Zhenglian Technology to supplement the following matters and requested lawyers to verify and provide clear legal opinions:
1. Concerning the ownership structure and changes in ownership: (1) the basis for not recognizing Hu Guangqing's spouse as a joint actual controller; (2) conclusions on the compliance of regulatory procedures involving foreign exchange management and foreign investment in the construction of the ownership structure; (3) information on the transfer of shares in January 2023, including the basic information of the new shareholders, reasons for investment, pricing basis for the new shares, and the existence of relationships between new shareholders and other shareholders, directors, supervisors, and senior management personnel; (4) clear conclusions on the legality and compliance of the establishment of the main operating entities and the various changes in ownership; (5) compliance with the reporting obligations of Zerolimit Holdings on foreign investment information.
2. Regarding the main business operations, please explain the specific functionalities and application scenarios of the main products by combining with the top five customers and their business types during the reporting period.
3. Regarding foreign investment access, please explain the specific plans for future value-added telecommunications services, the relevance to the main business, the specific business qualifications required, relevant foreign investment access policy regulations, and the progress of the business qualification application.
4. Regarding this issuance and listing plan, please explain the changes in the number of shares to be issued, the percentage of total equity after the issuance, the expected amount of funds to be raised (if any), a list of changes in the ownership structure before and after the issuance, and whether the controlling shareholder and actual controller will change after this issuance.
It is understood that Zhenglian Technology was established in August 2017 and is headquartered in Nanshan District, Shenzhen. In February 2023, Zero Limit Technology Holding Co. Ltd (Cayman) was established as the listing entity. The company is committed to providing comprehensive solutions for global users in the transition to the new generation of the Internet, providing digital solutions for governments, enterprises, and various industries and fields.
The company's distributed network infrastructure software products enable users to efficiently build distributed networks or migrate existing centralized applications to distributed networks. Application areas include digital government affairs, distributed online education, distributed search engines, distributed e-commerce, digital asset platforms, food traceability, Internet of Things, and smart manufacturing.
According to the prospectus, for the fiscal years of 2023 to 2024 (as of September 30th), the company's revenues were $5.68 million and $5.90 million respectively, with corresponding net profits of $2.52 million and $2.71 million.
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