United States securities and exchange commission logo
September 23, 2022
Leslie Yu
Chef Executive Officer
Quhuo Limited
3rd Floor, Block A, Tonghui Building, No. 1132 Huihe South Street
Chaoyang District Beijing 100020
The People s Republic of China
Re: Quhuo Limited
Form 20-F for the
Fiscal Year Ended December 31, 2021
Filed September 9,
2022
File No. 001-39354
Dear Ms. Yu:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2021
Item 4. Information on the company
B. Business Overview, page 60
1. When describing your
business, you state that you are a workforce operational solution
platform, that you
provide tech-enabled, end-to-end operational solutions, and that you
play a unique and
indispensable role as the link between consumer service businesses
and the end consumers
to enable the delivery of goods, services and experiences to
consumers. However,
it appears that these references to solutions, platforms,
technology, and being a
link do not explain in plain English what your actual service
offerings are and may
imply that you generate revenue directly from providing
technology, software,
platforms, or systems to customers. Please revise to state, if true,
that you deliver food
and products for third-party businesses, that you maintain and
transport bicycles for
bicycle rental companies, that you rent cars to ride-sharing drivers,
Leslie Yu
FirstName LastNameLeslie Yu
Quhuo Limited
Comapany 23,
September NameQuhuo
2022 Limited
September
Page 2 23, 2022 Page 2
FirstName LastName
and that you clean properties such as hotels, B&Bs and short-term
rentals. Please also
revise to reduce the amount of jargon in your business overview so
that investors can
more clearly understand the nature of your operations. Please provide
us with your intend
revised disclosure.
2. If our understanding above is correct, please also consider revising
captioning in tables
quantifying your revenue components to more directly describe the
service categories,
such as food and product deliveries, maintenance and transportation of
bicycle fleets,
housekeeping, and other.
3. You disclose that leveraging your technology capabilities, you conduct
data-driven
operational analysis to assist our industry customers in improving
their service quality and
consumer satisfaction. Please tell us if you earn revenue from such
analysis and, if so,
how it is measured and recognized.
Item 5. Operating and Financial Review and Prospects
Non-GAAP Financial Measures, page 90
4. You present an intermediate non-GAAP measure titled Adjusted net
income (loss). Please
tell us how you considered the requirement to tax-effect this measure
pursuant to Non-
GAAP C&DI 102.11.
Results of Operations, page 96
5. Please revise to quantify factors to which changes are attributed. For
example, you
disclose general and administrative expenses increased due to
increases in staff costs,
professional service fees, and impairment losses.
Index to Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition - On-demand delivery solutions, page F-20
6. We note that upfront payments to a customer for entering into a new
contract are initially
recognized as a non-current assets and reduce revenues on a
straight-line basis over an
anticipated relationship period of generally 8 years. You also state
that A delivery service
agreement typically is one year in term and is renewable by mutual
consent. Please tell
us how you determined that 8 years was the appropriate amortization
period.
Additionally, please quantify for us the total contract asset balance
for each period
presented, tell us which line item on the Consolidated Balance Sheet
it is included in, and
tell us how you classify such payments in your Consolidated Statements
of Cash Flows.
Please also tell us whether you provide additional consideration to
customers upon
contract renewal.
Note 13. Other Non-current Assets, page F-35
7. We note that rental and industry customer deposits appear to be a
significant component
Leslie Yu
Quhuo Limited
September 23, 2022
Page 3
of other Non- Current Assets. Accordingly, please revise the footnote
to disclose the
nature of these deposits and your related accounting policy.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Aamira Chaudhry at 202-551-3389 or Lyn Shenk at 202-551-
3380 with any questions.
FirstName LastNameLeslie Yu Sincerely,
Comapany NameQuhuo Limited
Division of
Corporation Finance
September 23, 2022 Page 3 Office of Trade &
Services
FirstName LastName