As advised by our PRC Legal Advisor, as such AI technology is solely used for our internal R&D purposes, it does not fall within the scope of application of any AI-related laws and regulations, and thus we did not violate any AI-related laws and regulations during the Track Record Period and up to the Latest Practicable Date.
In anticipation of potential licensing requirements associated with the continued development of our AI Computing Cloud Services, Beijing Yizhang proactively applied for an IDC license and obtained it on September 17, 2026.
Risk Factors · p. 41
The Company proactively applied for the IDC license considering that its expanding service offerings might be interpreted as requiring the IDC license and did not intentionally operate without an IDC license.
Risk Factors · p. 42
As advised by our PRC Legal Advisor, these circumstances fall within the circumstances for non-imposition of administrative penalties under the Administrative Penalty Law;
We did not develop AI large language models, provide generative AI services to the public in the PRC, or use algorithm recommendation or deep synthesis technologies to provide internet information services in the PRC.
Business · p. 141
Based on the above, our PRC Legal Advisor is of the view that the requirements under the PRC AI Regulations do not apply to our business.
Accordingly, we are not subject to the Administrative Measures for Internet Information Services (《互聯網信息服務管理辦法》) or related licensing or permit requirements, and its business does not involve foreign investment access restrictions applicable to internet information services.
As of the Latest Practicable Date, we had not applied for such security assessment or completed the algorithm filing procedures, as we do not consider these obligations to apply to our current business operations.
Risk Factors · p. 47
our onshore AI-related services do not currently constitute the provision of GenA.I. services to the onshore public, do not fall within typical scenarios with public opinion attributes or social mobilization capabilities (such as short videos, online live streaming, chat rooms, mini-programs, etc.), and are therefore unlikely to be subject to the security assessment and model filing requirements under the Interim Measures.
Our Group has completed algorithm filings and safety assessments for generative AI service with the Cyberspace Administration for the generated AI services it has launched in accordance with the Generative AI Services Measures and the Administrative Provisions on Deep Synthesis of Internet Information Service.
Business · p. 184
Based on the above, as advised by the PRC Legal Advisors, our Directors are of the view, and the Sole Sponsor concurs, that our Group is in compliance with all applicable laws and regulations on algorithm and artificial intelligence-related in all material respects during the Track Record Period and as of the Latest Practicable Date.
Furthermore, as advised by our PRC Legal Advisors, the operation of the Dtx software does not fall under the restricted or prohibited businesses under applicable PRC laws and regulations.
Additionally, we have completed the deep synthesis service algorithm filing for the Xiaozhuo AI Intelligent Conversation Assistant (Filing No.: 網信算備 370303094744901250011) and have conducted a security assessment.
Business · p. 169
As advised by our PRC Legal Advisers and PRC Data Compliance Legal Advisers, during the Track Record Period and up to the Latest Practicable Date, our Directors are of the view, and the Sole Sponsor concurs, that we are not aware of any material breaches or violations in relation to the Interim Administrative Measures on Generative Artificial Intelligence Services and applicable regulations related to generative AI services that would have a material adverse effect on our business, financial condition or results of operations.
In February 2026, the European Commission opened a formal investigation against us under the DSA in relation to (i) the systems we have in place to limit the sale of illegal products in the EU, (ii) the risks linked to the design of our service, as well as the systems we have in place to mitigate such risks, and (iii) the transparency of our recommender systems.
Risk Factors · p. 84
We are cooperating with the European Commission in this investigation, which remains at an early stage.