深演智能赴香港上市备案反馈意见，涉新三板未挂牌情况、搭建及拆除VIE架构原因等

Core Viewpoint - DeepZero Technology Co., Ltd. (Deep AI) has submitted its prospectus for an IPO in Hong Kong, with the China Securities Regulatory Commission requesting additional information regarding its previous attempts to list and its business operations [1][2][3]. Group 1: Listing and Regulatory Compliance - The company previously obtained approval from the National Equities Exchange and Quotations but did not proceed with the public transfer, raising questions about its intentions for A-share listing and any potential impacts on the current IPO [1]. - The company is required to clarify the reasons for establishing and dismantling offshore and VIE structures, including any violations of foreign exchange regulations and the status of any administrative penalties [1][2]. - The company must explain its smart advertising business in layman's terms and confirm compliance with relevant regulations regarding internet advertising [1][2]. Group 2: Business Operations and Data Management - The company is asked to detail its business scope, including internet information services and cultural exchange activities, and confirm whether it has the necessary licenses and whether its operations fall within restricted foreign investment areas [2]. - The company needs to disclose its involvement in developing and operating websites, apps, and other digital products, including the types of information provided to third parties and measures for data security and user information protection [2][3]. - The company must clarify whether the shares held by shareholders participating in the "full circulation" are subject to any pledges, freezes, or other rights defects [3]. Group 3: Market Position - Established in 2009, Deep AI is recognized as a leading decision-making AI technology company in China, particularly in the marketing and sales sectors, leveraging advanced AI algorithms and multimodal data [3]. - According to Frost & Sullivan, Deep AI ranks first in the Chinese marketing and sales decision-making AI application market by revenue in 2024 [3].