The Zhitong Finance App learned that on August 25, the China Securities Regulatory Commission announced supplementary material requirements for overseas issuance and listing registration (August 18, 2023 to August 24, 2023), and the International Department of the Securities Regulatory Commission issued supplementary material requirements for 7 companies. It requires Jinxin Technology Holding Company (Jinxin Technology) to provide additional explanations on the following matters, and request lawyers to check and issue clear legal opinions:

1. Regarding the control structure of the agreement, (1) Please explain the reasons why shareholders at the listed entity level do not match the shareholders and shareholding ratios of Shanghai Jinxin Network Technology Co., Ltd., the main domestic operating entity, and explain the risks and countermeasures that may be caused by the relevant arrangements, such as stable control rights and default of relevant entities. Please also explain the reasons why Shanghai Jinxin shareholders transferred their shares for 0 yuan in June 2022 and the tax payment status (if applicable); (2) the reason why Shanghai Rice Box and Shanghai Jinxin and their shareholders re-signed the VIE agreement in 2023.

2. Regarding shareholder information, please explain the time, type and operation method of the shareholder Wu Capital Family Trust, the upper level trust of Wu Capital Limited, the trust period, the rights and obligations of the parties, and the beneficiaries.

3. Regarding standardized operation, it is proposed to explain whether digital education content related to all types of business of your company is provided to the outside world through apps and applets developed and operated, the basis for determining the type of application filing and implementation of the filing procedure, whether it involves major copyright disputes, the scale of collection and storage of user information, data collection and use, whether there are situations of provision to third parties, and arrangements or measures for personal information protection and data security before and after listing.

4. Regarding equity incentives, please explain the legal compliance of the equity incentive plan and the scope of granting reserved rights, and whether there are situations where outsiders or who are not clearly granted.

According to reports, on August 10, 2023, Jinxin Technology publicly disclosed its prospectus at the US Securities Regulatory Commission (SEC) and plans to be listed on the US NASDAQ. The stock code is yet to be determined. It secretly filed a prospectus with the SEC on March 27, 2023.

The well-known product and brand of Jinxin Technology is Nano Box. The Nano Box app was launched in 2014. It was once an educational app famous for its work together and fun dubbing. It is very popular among primary and secondary school teachers and parents, and currently has 35.3 million registered users. As an innovative digital content service provider, Nanobox mainly uses a powerful digital content generation engine driven by advanced AI/AR/VR/digital human technology, and is committed to providing users with high-quality digital content services through its own platforms and content distribution channels with strong partners.