IPO News | Dongxin Marketing's proposed Hong Kong stock IPO, China Securities Regulatory Commission requires additional explanation of the operating entity's specific business and other matters

The Zhitong Finance App learned that on April 11, the China Securities Regulatory Commission issued the “Notice on Supplementary Material Requirements for Overseas Issuance and Listing (April 3, 2025 to April 10, 2025)”. The International Department of the Securities Regulatory Commission issued supplementary material requirements for 7 companies. Among them, the announcement mentions that Dongxin Marketing is required to further explain the specific business of the operating entities within the company, the service model or content related to digital marketing solutions that constitute the main source of revenue, and explain matters such as the main compliance measures taken in data security and privacy protection. According to the Hong Kong Stock Exchange's disclosure on January 15, Dongxin Marketing submitted a statement to the main board of the Hong Kong Stock Exchange, with Haitong International and Bank of China International as co-sponsors.

The Securities Regulatory Commission requested the company to further explain the following matters, and ask lawyers to check and issue clear legal opinions:

1. Please explain in plain language the business model and core competitiveness and the service model or content related to digital marketing solutions that constitute the main source of revenue, and the specific meaning of the relevant data collection method, whether it involves the collection and use of personal information and the specific scale (if applicable), and the main compliance measures taken in data security and privacy protection, taking into account the main products or businesses, major customers and suppliers, industry positions, and comparable companies in the same industry.

2. Please further explain: (1) Concluding opinions relating to the compliance of foreign exchange registration, foreign investment, foreign investment, taxation and other regulatory procedures involving the establishment of an offshore structure and return investment; (2) the pricing basis, payment method, payment period and compliance of shares in the domestic operating entity Shenzhen Dongxin Times through capital increases and equity transfers in 2021, and the fairness of the acquisition pricing process. Whether the tax filing and payment situation of the transferor related to the above equity transfer process complies with the “Regulations on mergers and acquisitions of domestic enterprises by foreign investors”; (3) the structure of shares established by foreign investors The reason why your company did not hold all of Shenzhen Dongxin Times's shares, but held 98.5% of Shenzhen Dongxin Era's shares and 1.5% of the shares through Dongxinxin Hong Kong, respectively; (4) Concluding opinions on the establishment of your company and major domestic operating entities and compliance with previous shareholding changes.

3. Please list the specific business of the entities operating within your company, the specific division of labor in the overall business layout of your company, and explain in light of the above situation that the relevant entities have obtained the necessary qualifications and licenses (if applicable) for business operations, and whether foreign investment prohibits or restricts the capital.

4. According to the filing report, GIMC HK, the shareholder holding 11.97% of your company's shares, is preparing to apply for a state-owned stock logo. Please explain the detailed processing progress.

According to the prospectus, Dongxin Marketing is an AI marketing company that drives development with AI, big models and big data technology. Since its establishment in 2004, it has continued to lead the R&D, innovation and application of marketing technology and full-stack AI marketing products, reaching the two trillion-level business scenarios of digital intelligence marketing and digital intelligence commerce. The company provides a full range of digital intelligence marketing and digital intelligence business solutions. Using AI marketing technology, the company creates commercial value for customers in thousands of industries and maximizes marketing effectiveness and efficiency.

According to Frost & Sullivan, in terms of revenue in 2023, the company is the largest AI marketing company in China, with a market share of 5.0%, and is the fastest growing participant among the top five AI marketing companies in China, with a revenue growth rate of 38.9% from 2022 to 2023.