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United States securities and exchange commission logo
September 7, 2023
Handong Cheng
Chief Executive Officer
ZW Data Action Technologies Inc.
Room 1811, Xinghuo Keji Plaza, No. 2 Fufeng Road
Fengtai District, Beijing, PRC
Re: ZW Data Action
Technologies Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2022
Response dated
August 24, 2023
File No. 001-34647
Dear Handong Cheng:
We have reviewed your August 24, 2023 response to our comment
letter and have the
following comment.
Please respond to this comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2022
Item 9C. Disclosure Regarding Foreign Jurisdiction that Prevent
Inspections, page 64
1. We note your statement
that you reviewed public filings and your material contracts in
connection with your
required submission under paragraph (a). Please supplementally
describe any additional
materials that were reviewed and tell us whether you relied upon
any legal opinions or
third party certifications such as affidavits as the basis for your
submission.
Please contact Kyle Wiley at (202) 344-5791 or Christopher Dunham
at (202) 551-3783
with any other questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program