September 18, 2018
Xiaoping Chen
Chairman and Chief Executive Officer
Viomi Technology Co., Ltd
Wansheng Square, Rm 1302 Tower C
Xingang East Road, Haizhu District
Guangzhou, Guangdong, 510220, PRC
Re: Viomi Technology Co., Ltd
Amendment No. 1 to Form F-1
Filed on September 11, 2018
File no. 333-227063
Dear Mr. Chen:
We have reviewed your amended registration statement and have the
following
comment. Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe our comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.
After reviewing any amendment to your registration statement and the
information you
provide in response to this comment, we may have additional comments.
Amendment No. 1 to Form F-1
Prospectus Summary
Corporate History and Structure, page 3
1. Please revise the corporate chart on pages 6 and 71 that shows the
company's structure
after the offering to also disclose the percentage voting power held by
the material
beneficial owners and investors in the offering.
Xiaoping Chen
Viomi Technology Co., Ltd
September 18, 2018
Page 2
You may contact Joseph Cascarano, Staff Accountant, at 202-551-3376 or
Robert S.
Littlepage, Accountant Branch Chief, at 202-551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415 or Kathleen Krebs, Special Counsel, at 202-551-3350
with any other
questions.
FirstName LastNameXiaoping Chen Sincerely,
Comapany NameViomi Technology Co., Ltd
Division of
Corporation Finance
September 18, 2018 Page 2 Office of
Telecommunications
FirstName LastName