Cloopen Group Holding Ltd (RAASY) – SEC staff letter

Staff comment: We note your proposed disclosure in response to prior comment 1. Please further revise your proposed disclosure to remove the exclusion of Hong Kong and Macau from the definition of "PRC" and "China." Revise to clearly state that all the legal and operational risks associated with having operations in the People’s Republic of China (PRC) also apply to operations and entities in Hong Kong and Macau. This disclosure could appear in the definition itself or in an appropriate discussion of legal and operational risks. To the extent you do not have material operations in Hong Kong and/or Macau, as you indicate in your response, you may provide disclosure to this effect. However, we also note… letter →

Staff comment: In your response to prior comment 2 you provide proposed revised disclosure of the referenced risk factor and Item disclosures. Please confirm that you intend to provide similar disclosure in the Item 3 disclosures regarding The Holding Foreign Companies Accountable Act. letter →