According to Zhichuang Financial APP, on September 1st, the China Securities Regulatory Commission announced the requirements for supplementary materials for overseas issuance and listing registration (from August 25th to August 31st, 2023). The International Department of the China Securities Regulatory Commission has issued supplementary materials requirements for seven enterprises. Among them, Qiniu Intelligence has been requested to provide supplementary explanations on the agreement control architecture, shareholders holding more than 5%, and other matters. Lawyers are requested to verify and provide clear legal opinions. It is reported that on June 29th, the Hong Kong Stock Exchange announced that Qiniu Intelligence Technology Co., Ltd. has submitted an application for listing on the main board of the Hong Kong Stock Exchange, and Shenwan Hongyuan HK and BOCOM International are the joint sponsors.

1. Regarding the agreement control architecture, please explain: (1) the compliance of domestic individuals and institutions holding the issuer's shares indirectly through Dream Galaxy Holdings Limited, Dustland Ltd., Qiming Venture Partners III, L.P., Magic Logistics Investment Limited and EverestLu Holding Limited with foreign exchange management, foreign investment and other regulatory procedures ; (2) the specific situation of building the agreement control architecture, including but not limited to the historical evolution of the agreement control architecture, and the specific reasons for resigning the VIE agreement in 2023; (3) the reasons for the inconsistency of shareholders between the issuer's shareholders and Qiniu Information and Kongshan Information's shareholders and their shareholding ratios at the main domestic operating entities and the issuer level, and explain the control stabilisation, the risks of default by relevant parties, and countermeasures that may be caused.

2. Regarding shareholders holding more than 5% of the shares: (1) Salient Growth Investco Limited, the investor of Qiming Venture Partners III, L.P., penetrates upwards to include a Chinese domestic state-owned holding entity. Please explain the basic situation of this state-owned holding entity; (2) the situation of the investor after Yunfeng Fund II AIV, L.P. penetrates upwards is there any situation where it violates laws and regulations that prohibit shareholding, etc.

3. Regarding state-owned shareholders, please explain the state-owned asset management procedures such as Shanghai Zhangjiang Science and Technology Investment Co., Ltd., BOCOM International Asset Management Limited, Shanghai (Z.J.) Holdings Limited, and EverestLu Holding Limited's state-owned shareholding identification.

4. Regarding the controlling shareholders: (1) The shareholding ratios of the company's first and second largest shareholders are close. Please explain whether Xu Shiwei and the first and second largest shareholders have a consistent action agreement or similar arrangement; (2) Combined with the shareholders' meeting, board voting, and director appointment situation, please explain the specific basis for Xu Shiwei to actually control the issuer through investment relationships, agreements or other arrangements.

5. Regarding data collection and processing, the company's main business involves data storage, processing, and analysis, as well as interactive live broadcasts. Please explain the products developed, operated, such as website, APP, mini-program, etc, the operating entities of the above products, the scale of collecting and storing user information, the use of data collection, whether there is a situation of providing information to third parties, and arrangements or measures for personal information protection and data security after listing.

6. Regarding shareholding changes, please explain the definitive opinions on the legality and compliance of share changes since the establishment of the main domestic operating entities.

According to the prospectus, based on the revenue in 2022 by Ai Rui Consulting, Qiniu Intelligence is the third largest video and audio PaaS (Platform as a Service) service provider in China, second only to the video and audio PaaS business of the two largest Internet companies in China, with a market share of 5.7%. According to Ai Rui Consulting, based on the revenue of APaaS in 2022, the company is also the second largest audio and video APaaS service provider in China, second only to one of the largest Internet companies in China, with a market share of 11.9%.

As one of the earliest platforms to provide audio and video cloud services in China, Qiniu Intelligence is one of the few companies with comprehensive and high-performance MPaaS products and technical capabilities that integrate and cover every aspect of audio and video business. The company's MPaaS product uses a series of audio and video technologies (including RTC, on-demand, live, storage, and content distribution) and AI technologies (including intelligent vision, intelligent voice, intelligent editing, industry algorithms, content security and business security). Through the company's proprietary technology, the company achieves widespread network coverage, comprehensive node monitoring, and real-time intelligent allocation, providing customers with high-quality, low-latency cloud services.