
Zhenglian Technology (Zero Degree Digital Group) plans to list on the US stock market, and the China Securities Regulatory Commission requires supplementary explanations regarding its main business activities and other situations

Zhenglian Technology (Zero Degree Digital Group) plans to go public on NASDAQ, intending to issue 2 million common shares at an offering price of $4 per share, raising $8 million, with an expected market value of up to $200 million. The China Securities Regulatory Commission requires it to provide additional explanations regarding its main business content, including the functions and application scenarios of its main products, as well as matters related to its equity structure and compliance with foreign investment regulations
According to the Zhitong Finance APP, on August 1, the China Securities Regulatory Commission (CSRC) announced the "Supplementary Material Requirements for Overseas Issuance and Listing Filing (July 25, 2025 - July 31, 2025)," in which the International Department of the CSRC issued supplementary material requirements for 9 companies. Among them, Zhenglian Technology (Lingji Digital Group) (private placement to public offering) is required to supplement the description of its main business content, including explaining the specific functions and application scenarios of the company's main products in conjunction with the top five customers and their business types during the reporting period. It is reported that Zhenglian Technology (Shenzhen) Co., Ltd. plans to go public on NASDAQ, intending to issue 2 million ordinary shares at a price of $4 per share, raising $8 million, with an expected market capitalization of up to $200 million.
The CSRC requests Zhenglian Technology to supplement the following matters and asks lawyers to verify and provide clear legal opinions:
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Regarding the equity structure and changes in equity, (1) the basis for not recognizing Hu Guangqing's spouse as a co-actual controller; (2) conclusive opinions on the compliance of foreign exchange management, foreign investment, and other regulatory procedures involved in the equity structure setup; (3) the basic situation of new shareholders related to the equity transfer of Zhenglian Technology in January 2023, reasons for investment, pricing basis for the investment price, and whether there are any related relationships between new shareholders and other shareholders, directors, supervisors, and senior management; (4) clear conclusive opinions on the legality and compliance of the establishment of the main domestic operating entity and its historical equity changes; (5) the fulfillment of foreign investment information reporting obligations by Lingji Holdings.
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Regarding the main business content, please explain the specific functions and application scenarios of the company's main products in conjunction with the top five customers and their business types during the reporting period.
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Regarding foreign investment access, please explain the specific plans for future value-added telecommunications business, its relevance to the main business, the specific business qualifications required, relevant foreign investment access policy regulations, and the progress of business qualification applications.
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Regarding this issuance and listing plan, please explain the number of shares issued, the proportion of total share capital after issuance, the expected amount of funds raised (if any), and list the changes in the equity structure before and after the issuance, as well as whether the controlling shareholder and actual controller change after this issuance.
It is understood that Zhenglian Technology was established in August 2017 and is headquartered in Nanshan District, Shenzhen. In February 2023, it established Zerolimit Technology Holding Co., Ltd. (Cayman) as the listing entity. The company is committed to providing comprehensive solutions for global users in the transition to a new generation of the Internet, offering digital solutions for government enterprises and various industries and fields.
The company's distributed network infrastructure software products enable users to efficiently build distributed networks or migrate existing centralized applications to distributed networks. Application areas include digital government, distributed online education, distributed search engines, distributed e-commerce, digital asset platforms, food traceability, the Internet of Things, intelligent manufacturing, and more.
The prospectus shows that for the fiscal years 2023 to 2024 (ending September 30), the company's revenue is projected to be $5.68 million and $5.90 million, with corresponding net profits of $2.52 million and $2.71 million