1. 本法律意见书是本所律师根据出席本次股东大会所掌握的法律事实及初灵信息 提供的有关资料发表法律意见。 2. 初灵信息已向本所律师保证和承诺，其所提供的所有文件正本及副本均为真实、 完整，初灵信息已向本所律师披露一切足以影响本法律意见书出具的事实和文件，且无 任何隐瞒、疏漏之处。 浙江星韵律师事务所 关于杭州初灵信息技术股份有限公司 2025 年第一次临时股东大会的法律意见书 致：杭州初灵信息技术股份有限公司 根据《中华人民共和国公司法》（以下简称"《公司法》"）、《中华人民共和国 证券法》（以下简称"《证券法》"）、《上市公司股东会规则》（以下简称"《股东 会规则》"）及《杭州初灵信息技术股份有限公司章程》（以下简称"《公司章程》"） 的有关规定，浙江星韵律师事务所（以下简称"本所"）受杭州初灵信息技术股份有限 公司（以下简称"初灵信息"或"公司"）的委托，委派律师（以下简称"本所律师"） 出席2025年10月17日下午召开的初灵信息2025年第一次临时股东大会（以下简称"本次 股东大会"），对会议现场进行律师见证，并出具本法律意见书。 律师声明事项： 3. 本所律师按照《股东会规则》的要求，对初灵信息提 ...

证券代码：300250 证券简称：初灵信息 公告编号：2025-052 杭州初灵信息技术股份有限公司 2、申报地点及申报材料送达地点 关于注销回购股份通知债权人的公告 本公司及董事会全体成员保证信息披露内容的真实、准确、完整，没有虚假 记载、误导性陈述或重大遗漏。 一、公司变更回购股份用途并注销的情况 杭州初灵信息技术股份有限公司（以下简称"公司"）于 2025 年 9 月 29 日 召开第五届董事会第二十二次会议及 2025 年 10 月 17 日召开的 2025 年第一次临 时股东大会审议通过了《关于变更部分回购股份用途并注销的议案》、《关于减 少注册资本暨修订<公司章程>的议案》，为了维护广大投资者利益，增强投资者 的投资信心，根据公司实际经营管理情况，结合公司整体战略规划、库存股情况 等因素综合考量。公司拟对于 2025 年 1 月 3 日召开的第五届董事会第十八次会 议审议通过的《关于回购公司股份方案的议案》所实施回购的股份中的 318,000 股用途，由"为维护公司价值及股东权益所必需，回购的股份将在披露本回购完 成公告十二个月后根据相关规则予以出售"变更为"用于注销并相应减少注册资 本"，即拟对 ...

Core Viewpoint - Chuling Information's stock price has shown significant volatility, with a year-to-date increase of 73.19%, but a recent decline of 12.82% over the past five trading days [1] Group 1: Stock Performance - On October 17, Chuling Information's stock rose by 2.09%, reaching 24.42 CNY per share, with a trading volume of 300 million CNY and a turnover rate of 7.95%, resulting in a total market capitalization of 5.228 billion CNY [1] - The stock has experienced a net outflow of 1.2985 million CNY from main funds, with large orders buying 42.0311 million CNY (14.01%) and selling 45.7499 million CNY (15.25%) [1] - The stock has appeared on the "Dragon and Tiger List" 11 times this year, with the most recent appearance on October 13, showing a net buy of -42.0441 million CNY [1] Group 2: Company Overview - Chuling Information, established on December 10, 1999, and listed on August 3, 2011, is located in Hangzhou, Zhejiang Province, and specializes in information access solutions and big data application services [2] - The company's revenue composition includes: Smart Connection (42.45%), Data Perception (32.32%), Smart Application Development and Services (16.48%), and Others (8.75%) [2] - As of September 19, the number of shareholders increased by 10.32% to 31,000, with an average of 5,086 circulating shares per person, a decrease of 9.35% [2] Group 3: Financial Performance - For the first half of 2025, Chuling Information reported a revenue of 115 million CNY, a year-on-year decrease of 8.23%, while the net profit attributable to shareholders was 3.4469 million CNY, a year-on-year increase of 117.39% [2] - The company has distributed a total of 162 million CNY in dividends since its A-share listing, with no dividends paid in the last three years [3]

Core Insights - The stock of Chuling Information experienced a decline of 4.32% with a turnover rate of 37.76% and a trading volume of 1.637 billion yuan, indicating significant market activity [2] - Institutional investors net sold 29.8644 million yuan, while brokerage seats collectively net bought 570,200 yuan [2] - The stock has been listed on the Dragon and Tiger list 10 times in the past six months, with an average price increase of 2.88% the day after being listed and an average increase of 6.29% in the following five days [3] Trading Activity - On the trading day, the top five brokerage seats accounted for a total transaction volume of 400 million yuan, with buying amounting to 185 million yuan and selling amounting to 215 million yuan, resulting in a net sell of 29.2942 million yuan [2] - Specific trading details show that five institutional seats were involved in both buying and selling, with total buying of 169 million yuan and total selling of 199 million yuan, leading to a net sell of 29.8644 million yuan [2] Fund Flow - The stock saw a net outflow of 57.0836 million yuan in principal funds today, with a significant outflow of 30.8748 million yuan from large orders and 26.2088 million yuan from major orders [3] - Over the past five days, the stock has experienced a net inflow of 77.1727 million yuan in principal funds [3]

Core Insights - Chuling Information's stock rose by 12.94% with a turnover rate of 47.82% and a trading volume of 2.053 billion yuan, indicating strong market interest [2] - Institutional investors net bought 42.4471 million yuan, while the total net buying from brokerage seats was 5.7638 million yuan [2] - The stock has appeared on the Dragon and Tiger list 9 times in the past six months, with an average price increase of 3.78% the day after being listed and an average increase of 10.04% over the following five days [2] Trading Data - The top five brokerage seats accounted for a total transaction of 413 million yuan, with a buying amount of 231 million yuan and a selling amount of 182 million yuan, resulting in a net buying of 48.2109 million yuan [2] - Specific trading data shows that five institutional seats were involved in buying, with a total buying amount of 20.9 million yuan and a selling amount of 16.7 million yuan, leading to a net buying of 42.4471 million yuan [2] Fund Flow - The stock experienced a net inflow of 114 million yuan from main funds, with a significant inflow of 104 million yuan from large orders and 10.026 million yuan from medium orders [2] - Over the past five days, the net inflow of main funds totaled 33.1651 million yuan [2]

New Stock Listings - New stock "Aomeisen" (920080) listed at an issue price of 8.25 on October 10, 2025[1] - "Shangwei New Materials" (688585) has a tender offer period from September 29 to October 28, 2025[1] Delisting and Trading Alerts - "Zitian Tui" (300280) is in the delisting arrangement period with only 1 trading day remaining[1] - "Pinming Technology" (688109) is experiencing severe abnormal fluctuations[1] Market Updates - Multiple companies including "Kesi Technology" (688788) and "Bory Medical" (688166) have recent announcements related to trading activities[1] - "Ganfeng Lithium" (002460) and "Luoyang Molybdenum" (603993) have also made recent disclosures[1] Additional Information - A total of 30 companies have been highlighted for various trading activities and announcements on October 10, 2025[1] - Links to detailed announcements for each company are provided for further insights[1]

Market Overview - The Shanghai Composite Index closed at 3913.80 points, above the five-day moving average, with a decline of 0.51% [1] - The total trading volume of A-shares reached 16560.95 billion yuan [1] Stocks Performance - A total of 737 A-shares have surpassed the five-day moving average today [1] - Stocks with significant deviation rates include: - Chuling Information (300250) with a deviation rate of 9.06% and a daily increase of 12.94% [1] - Seven Wolves (002029) with a deviation rate of 9.01% and a daily increase of 10.01% [1] - Aonong Biological (603363) with a deviation rate of 7.74% and a daily increase of 10.04% [1] - Stocks with smaller deviation rates that just crossed the five-day moving average include: - Zhongjing Food (not specified) and Jincheng New Materials (not specified) [1] Detailed Stock Data - The following stocks showed notable performance: - Chuling Information (300250): Latest price 28.01 yuan, five-day moving average 25.68 yuan, turnover rate 37.07% [1] - Seven Wolves (002029): Latest price 9.12 yuan, five-day moving average 8.37 yuan, turnover rate 5.63% [1] - Aonong Biological (603363): Latest price 5.37 yuan, five-day moving average 4.98 yuan, turnover rate 6.52% [1] - Other notable stocks include: - Narl Co. (002825) with a 10.04% increase and a deviation rate of 7.70% [1] - HNA Technology (600751) with a 9.93% increase and a deviation rate of 7.56% [1]

Market Overview - The Shanghai Composite Index is at 3927.63 points, slightly down by 0.16%, and remains above the five-day moving average [1] - The total trading volume of A-shares today is 12,445.99 billion [1] Stocks Performance - A total of 751 A-shares have surpassed the five-day moving average today [1] - Notable stocks with significant deviation rates include: - Chuling Information (乖离率 9.55%) - Seven Wolves (乖离率 9.01%) - Aonong Biological (乖离率 7.27%) [1] Top Stocks by Deviation Rate - The following stocks have the highest deviation rates from the five-day moving average: - Chuling Information: Today's change +13.59%, turnover rate 31.60%, latest price 28.17 [1] - Seven Wolves: Today's change +10.01%, turnover rate 5.46%, latest price 9.12 [1] - Aonong Biological: Today's change +9.43%, turnover rate 5.15%, latest price 5.34 [1] - Other notable stocks include: - Zhaolang Intelligent: +10.18%, turnover rate 7.14%, latest price 3.14 [1] - Taotao Automotive: +8.57%, turnover rate 6.91%, latest price 229.63 [1]

Core Viewpoint - Chuling Information's stock dropped by 8.82% with a turnover rate of 35.55%, indicating significant trading activity and potential volatility in the market [2] Trading Activity - The total trading volume for Chuling Information reached 1.425 billion yuan, with a price fluctuation of 12.15% throughout the day [2] - Institutional investors net bought 10.8012 million yuan, while brokerage seats collectively net sold 23.264 million yuan [2] - The stock was listed on the Shenzhen Stock Exchange's "Dragon and Tiger List" due to its high turnover rate [2] Institutional Participation - The top five trading departments accounted for a total transaction volume of 287 million yuan, with buying transactions amounting to 137 million yuan and selling transactions totaling 150 million yuan, resulting in a net sell of 12.4628 million yuan [2] - Six institutional specialized seats were involved in trading, with total buying amounting to 137 million yuan and selling amounting to 126 million yuan, leading to a net buy of 10.8012 million yuan [2] Recent Performance - Over the past six months, Chuling Information has appeared on the "Dragon and Tiger List" eight times, with an average price increase of 2.48% the day after being listed and an average increase of 2.25% over the following five days [2] Capital Flow - The stock experienced a net outflow of 85.4714 million yuan in principal funds, with a significant outflow of 62.4178 million yuan from large orders and 23.0536 million yuan from medium orders [2] - In the last five days, the net outflow of principal funds totaled 133 million yuan [2]

Core Insights - On September 30, a total of 39 stocks were involved with institutional investors, with 22 showing net buying and 17 showing net selling [1] Group 1: Institutional Buying - The top three stocks with the highest net buying by institutions were Huahong Company, Duofluo, and Xingye Yinxin, with net buying amounts of 684 million, 332 million, and 320 million respectively [1] - Other notable stocks with institutional net buying included Huijin Co. (22 million), Hunan Yunan (18 million), and Tianji Co. (7.75 million) [2] Group 2: Institutional Selling - The top three stocks with the highest net selling by institutions were Huagong Technology, Huasoft Technology, and Chuling Information, with net outflow amounts of 726 million, 64 million, and 58 million respectively [1] - Additional stocks with significant institutional net selling included Fulin Precision (41 million), Jingxing Paper (55 million), and Huasoft Technology (64 million) [4]