On August 25th, according to the news from the Wall Street Journal, China Securities Regulatory Commission released the supplemental material requirements for overseas IPO filing (August 18th, 2023 - August 24th, 2023), and the International Department of the CSRC issued supplemental material requirements for 7 enterprises. Among them, Jinxin Technology Holding Company has been asked to provide supplementary explanations on the following issues. Please have the lawyers verify and provide clear legal opinions:

I. Regarding the agreement control structure, (1) please explain the reasons for the inconsistency in shareholding and shareholding ratios between the shareholders of the listed subject and the major domestic operating entity Shanghai Jinxin Network Technology Co., Ltd., and explain the risks and countermeasures related to the stability of control rights, breaches by relevant subjects, etc. Please also explain why Shanghai Jinxin shareholders transferred equity for 0 yuan in June 2022 and the tax payment status (if applicable); (2) please explain the reasons why Shanghai Mihe and Shanghai Jinxin and their shareholders signed a new VIE agreement in 2023.

II. Regarding shareholder information, please explain the establishment time, type, mode of operation, term, arrangement of rights and obligations of the parties, beneficiaries, etc. of Wu Capital Family Trust, an upper-level trust of shareholder Wu Capital Limited.

III. Regarding standardized operations, please explain whether all the digital educational content related to your company's various businesses are provided to the public through APPs and mini-programs developed and operated by your company, the basis for determining the type of APP filing, and the fulfillment of filing procedures, whether there are significant copyright disputes, the scale of user information collection and storage, data collection and usage situation, whether there are cases of providing to third parties, as well as the arrangements or measures for personal information protection and data security before and after listing.

IV. Regarding equity incentives, please explain the legitimacy and compliance of the stock incentive plan, as well as the scope of granting reserved equity rights, and whether there are cases of external personnel and undefined recipients.

According to the news, on August 10th, 2023, Jinxin Technology publicly disclosed the prospectus to the US Securities and Exchange Commission (SEC), and plans to list on the NASDAQ in the US, and the stock code has not been determined. It secretly submitted the prospectus to SEC on March 27, 2023.

Jinxin Technology, known for its product and brand Nanohe, launched the Nanohe APP in 2014, which was a well-known education APP that was on par with apps such as Together with Homework and Fun Dubbing. It has high visibility among teachers and parents in primary and secondary schools. At present, it has 35.3 million registered users. As an innovative digital content service provider, Nanohe relies mainly on a powerful digital content generation engine driven by advanced AI/AR/VR/digital human technology. It is committed to providing high-quality digital content services to users through its own platform and the strong content distribution channels of its partners.