United States securities and exchange commission logo
February 2, 2022
Huihe Zheng
Chairman of the Board, CEO, and President
QDM International Inc.
Room 715, 7F, The Place Tower C, No. 150 Zunyi Road
Changning District
Shanghai, China 200051
Re: QDM International
Inc.
Form 10-K for the
fiscal year ended March 31, 2021
Filed on July 12,
2021
Forms 10-K/A for
the fiscal year ended March 31, 2021
Filed October 21,
2021
Filed December 17,
2021
File No. 000-27251
Dear Mr. Zheng:
We have reviewed your December 17, 2021 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
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. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K/A for the fiscal year ended March 31, 2021, filed December 17,
2021
Business, page 1
1. At the onset of
Business in Part I., Item.1, and in a related risk factor in Item 1A, please
disclose whether your
auditor is subject to the determinations announced by the PCAOB
on December 16, 2021
and whether and how the Holding Foreign Companies
Accountable Act and
related regulations will affect your company.
You may contact Bonnie Baynes at (202) 551-4924 or Sharon Blume at
(202) 551-
3474 with any questions.
Huihe Zheng
QDM International Inc.
February 2, 2022
Page 2
FirstName LastNameHuihe Zheng Sincerely,
Comapany NameQDM International Inc.
Division of Corporation Finance
February 2, 2022 Page 2 Office of Finance
FirstName LastName