Zhitong Finance App learned that on October 23, the China Securities Regulatory Commission announced the requirements for supplementary materials for overseas issuance and listing registration (October 19, 2026 to October 23, 2026). The Securities Regulatory Commission requested Kiryu Technology to further explain whether there are equity intermediaries in historical history, and issue a concluding opinion on whether the issuer's establishment and successive equity changes are legal and compliant. According to the Hong Kong Stock Exchange's disclosure on April 29, Jiliu Technology submitted a listing application to the Hong Kong Stock Exchange, and Cathay Pacific Junan International was the sole sponsor.
In addition, the Securities Regulatory Commission requested Kiryu Technology to further explain the following matters, and ask lawyers to check and issue clear legal opinions:
Explanation (1) Whether the Jiliu Xiliu and Kiryu Xizawa partner company change registration has been completed, and whether there have been any changes in the filing materials; (2) Whether Xinglian Dingsen and Hangzhou Guangyue are registered private equity funds, if not, please carry out a penetrating inspection in accordance with the requirements of the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Class No. 2” (hereinafter referred to as “Regulatory Guidelines No. 2”); (3) Hangzhou Guangyue and Suzhou Guangyue are controlled by the same entity, and the shareholding ratio should be calculated together according to the shareholder standard of 5% or more.
Explanation (1) Complete verification of the new shareholder situation in the last 12 months in accordance with the requirements of the “Regulatory Guidelines No. 2”, including old shareholders who have acquired new shares in the last 12 months, and explain the transaction price, pricing basis, etc. in chronological order; (2) Explain the reasons for the differences in the shareholding prices of the new shareholders, and issue clear concluding opinions on whether the entry price is fair and reasonable and whether there is a transfer of benefits.
Explanation (1) In strict accordance with the “Regulatory Guidelines No. 2”, explain whether the new shareholders Yuanchuang Future Fund and Huahai Gimpo have situations where shareholders are prohibited by laws and regulations from directly or indirectly holding shares of the issuer's shares; (2) whether the relationships between the new shareholders, Shanghai Guofang, etc. and the sponsor Guotai Junan Finance Co., Ltd. affect the independence of intermediaries and whether they comply with the listing rules.
Explain (1) the reason and necessity for the issuer to set up multiple employee shareholding platforms, and whether the incentive prices and conditions of each platform are consistent; (2) whether Jiao Fangzheng has been in office for less than one year and has met the conditions for granting equity incentives; whether retaining the incentive share complies with the employee shareholding plan regulations or agreement agreements; (3) issue clear concluding opinions on whether the equity incentives are legal and compliant, the price is fair, and whether there are benefits.
Explain (1) whether the shares held by shareholders who intend to participate in “full circulation” have been pledged, frozen, or have other rights defects; (2) Please explain the progress of the state-owned shareholder Karamay City Development Fund in processing the state-owned stock logo. If processing is ongoing, please promise to complete the issuance before listing.
The maximum number of copies issued in the filing materials and prospectus should be consistent. If there are any inconsistencies, please provide a revised filing report or prospectus. If the prospectus involves increasing the amount of current issuance and the scale of capital raised, please also update the plan for the use of funds raised.
According to the prospectus, Kiryu Technology is the largest independent AI computing power cluster provider in China, leading disruptive innovation in the field of AI infrastructure. The rapid evolution of AI technology is driving society's growing demand for high-performance AI infrastructure. The bottleneck in designing and delivering high-performance AI infrastructure is not only high-performance computing and network chips themselves, but also whether tens of thousands of processors can be turned into a high-performance supercomputer through network systems, orchestration and scheduling mechanisms, and parallel computing technology.