SRSEC Reporting Desk

FiEE, Inc. (FIEE) – Company response

2026-04-30 · Re: · Accession 0001829126-26-004306 · Agreed to revise

China-Based IssuersBusiness Description (Item 101)

2026-04-30 · · Comment 1 · General Agreed to revise
Staff comment: We note that beginning in March 2025, the Company has derived all its revenues from Hong Kong. Please revise your filing to provide specific and prominent disclosures about the legal and operational risks associated with having your business in this location, consistent with the guidance in our Sample Letter to Companies Regarding China-Specific Disclosures and our Sample Letter to China-Based Companies, which were posted to our website July 17, 2023, and on December 20, 2021. U.S. letter →
Company response: The Company acknowledges the Staff’s comment and respectfully advises the Staff that the Company has revised the disclosure beginning on page 1 of the Form 10-K/A and beginning on page 4 of the Public Filing Form S-3 to address the legal and operational risks associated with having the Company’s revenue generating business in Hong Kong. Additionally, the Company has revised the disclosure beginning on page 13 of the Form 10-K/A to include risk factors related to doing business in Hong Kong. Please note that the Form 10-K/A is incorporated by reference into the Public Filing Form S-3. U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology If you should… response letter →
China-Based IssuersBusiness Description (Item 101)

Full letter on EDGAR → · Filing index · All FiEE, Inc. (FIEE) correspondence

China-Based Issuers – what to check: Address PRC regulatory, VIE structure, cash transfer and HFCAA disclosures prominently up front.

Business Description (Item 101) – what to check:

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