| August 16, 2022 | |
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Division of Corporation Finance U.S. Securities & Exchange Commission 100 F Street, NE Washington, D.C. 20549
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| Re: |
36Kr Holdings Inc. Form 20-F for Fiscal Year Ended December 31, 2020 Response dated June 27, 2021 File No. 001-39117 |
| Attn: |
Division of Corporation Finance Office of Trade & Services |
VIA EDGAR
Dear Jennie Beysolow and Dietrich King:
This letter sets forth the responses of 36Kr Holdings Inc. (“36Kr” or the “Company”) to the comment (the “Comment”) the Company received from the Securities and Exchange Commission (the “Commission”) in a letter dated August 9, 2022.
For your convenience, we have included herein the comment in bold, and the Company’s responses are set forth immediately below the Comment.
| Annual Report on Form 20-F for Fiscal Year Ended December 31, 2021 |
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Item 3, Key Information, page 1
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| 1. We note your revised disclosure in response to comment 4. We also note your disclosure that you “have not been subject to any material fines or other material penalties due to non-compliance with cybersecurity or data privacy laws or regulations.” In future filings, the disclosure here should not be qualified by materiality. Please make appropriate revisions to your disclosure. |
Response
The Company acknowledges the Staff’s comments. In response to the Staff’s Comments, the Company respectfully advises the Staff that it intends to revise the disclosure on page 45 of the 2021 Annual Report in its future filings as follows:
As of the date
of this annual report, we have not been involved in any investigations or become subject to a cybersecurity review initiated by the
CAC based on the Cybersecurity Review Measures, and we have not been subject
to any material fines or other material penalties due to non-compliance
with cybersecurity or data privacy laws or regulations and we have not received any inquiry, notice, warning, sanctions
in such respect or any regulatory objections to our listing status from the CAC. In
addition, (a) from time to time we have been communicating with the competent authorities, including the local branch of the CAC,
and will closely monitor and assess further regulatory developments regarding cybersecurity and data privacy laws, including the
development on cybersecurity review, and comply with the latest regulatory requirements or apply for cybersecurity review as applicable;
(b) we will continuously improve our data security protection technologies and internal control procedures and engage external professional
consultants to advise us on cybersecurity and data protection requirements, if needed. Based on the foregoing analysis, we believe
under the currently effective PRC laws and regulations, we are not required to go through a cybersecurity review by the CAC to conduct
a security offering or maintain our listing status on the Nasdaq. However, there remain substantial uncertainties on the interpretation
and implementations of the Cybersecurity Review Measures.
If you have further questions or comments regarding, or require further information or clarification of, any of the responses provided in this letter or if the Commission has any questions with respect to 36Kr Holdings Inc.’s Annual Report on Form 20-F, please contact the undersigned or Li He (Tel: +852-2533-3306) and Ran Li (Tel: +86-10-8567-5013) of Davis Polk & Wardwell LLP.
| Sincerely yours, | ||
| 36Kr Holdings Inc. | ||
| By: |
/s/ Dagang Feng | |
| Name: Dagang Feng | ||
| Title: Chief Executive Officer | ||
| cc: | Li He |
| Davis Polk & Wardwell LLP |