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中科星图: 北京市君合律师事务所关于中科星图股份有限公司2025年度向特定对象发行A股股票之补充法律意见书(一)
Zheng Quan Zhi Xing· 2025-06-27 16:50
Core Viewpoint - The document discusses the supplementary legal opinion regarding the issuance of A-shares by Zhongke Xingtou Co., Ltd. to specific investors in 2025, focusing on compliance with relevant laws and the necessity of the fundraising projects [3][4]. Group 1: Fundraising Projects - The total amount of funds to be raised from the issuance will not exceed RMB 1 billion, allocated for the construction of three main projects: the Flight Service Digital Infrastructure Platform, the Xingtou Luoshu Defense and Public Safety Big Data Intelligent Analysis Platform, and supplementary working capital [6][7]. - The company’s business includes data services, primarily selling data products processed from raw data using self-developed software [6][7]. - As of December 31, 2024, the funds raised from the company's initial public offering in 2020 and the specific issuance in 2021 have not been fully utilized [6][7]. Group 2: Compliance and Legal Assurance - The supplementary legal opinion confirms that the company has conducted thorough investigations and discussions to ensure compliance with relevant laws, including the Personal Information Protection Law, Data Security Law, and Cybersecurity Law [9][12]. - The company has obtained necessary business qualifications for the implementation of the fundraising projects, ensuring no violations in data procurement or services [9][12]. - The company has committed to taking measures to ensure that its data procurement and service operations comply with applicable laws and regulations [11][12]. Group 3: Project Implementation and Data Procurement - The projects have not yet provided data services to third parties, with only the Xingtou Cloud Project having conducted two preliminary data procurements [8][13]. - The data procurement for the Xingtou Cloud Project is legally compliant, with contracts ensuring that the supplier has the necessary qualifications and that the data provided does not violate any laws [8][13]. - The company has outlined specific data procurement and service content for each project, focusing on high-quality data sets and comprehensive services across various industries [8][9].