United States securities and exchange commission logo
October 24, 2022
Jiang Hui
Chief Executive Officer
Wave Sync Corp.
19 West 44th Street
Suite 1001
New York, NY 10036
Re: Wave Sync Corp.
File No. 1-34113
Correspondence
filed October 7, 2022
Dear Jiang Hui:
We have reviewed your 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. 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.
Correspondence filed October 7, 2022
Consolidated Statements of Operations, page F-5
1. We note your disclosure
that the cost of revenue includes clubhouse services but none of
the other costs
associated with rental income. It is also not clear what cost of services have
been included relating
to cryptocurrency. As such, your presentation of gross profit on the
statements of
operations appears to result in a non-GAAP measure that is based on
individually tailored
accounting principles as it does not contemplate all costs of sales.
Please remove the
presentation of gross profit or otherwise address the guidance in SAB
Topic 11B.
You may contact Al Pavot at 202.551.3738 or Terence O'Brien at
202.551.3355 if you
have questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services