According to Zhitong Finance APP, on September 30, the China Securities Regulatory Commission (CSRC) issued the "Supplementary Material Requirements for Overseas Issuance and Listing Filing (September 20, 2026 – September 30, 2026)." The International Department of the CSRC issued supplementary material requirements for a total of 5 companies. Among them, Purple X Technology was asked to supplement its explanation regarding the prices, pricing basis, and paid-in capital contributions for each capital increase, equity or share transfer, the legality and compliance of its establishment and previous equity changes, and whether there is any tunneling of benefits.
According to a disclosure by the Hong Kong Stock Exchange on June 24, Purple X Technology (Fujian) Co., Ltd. submitted a listing application to the Main Board of the Hong Kong Stock Exchange, with Guotai Junan International as its sole sponsor. The CSRC requested Purple X Technology to supplement the following matters and requested lawyers to verify and issue clear legal opinions:
1. Please explain: (1) the prices, pricing basis, and paid-in capital contributions for each capital increase, equity or share transfer of your company, whether there are abnormal share subscription prices, and whether there are circumstances of failure to fulfill capital contribution obligations, withdrawal of capital contributions, or defects in the method of capital contribution; (2) whether the foreign investment portions involved in each capital increase, equity or share transfer of your company comply with relevant regulations on foreign investment; (3) whether there has been any shareholding on behalf of others in the historical evolution of your company, and whether there are circumstances where entities prohibited by laws and regulations from holding shares directly or indirectly hold shares of the issuer; (4) please issue a clear conclusive opinion on the legality and compliance of the issuer's establishment and previous equity changes, as well as whether there is any tunneling of benefits.
2. Please refer to the requirements of the "Regulatory Rules Application Guidelines – Overseas Issuance and Listing No. 2": (1) explain the establishment background, personnel composition, price fairness, and performance of decision-making procedures of the employee stock ownership plan, and issue a clear conclusive opinion on whether the employee stock ownership plan is legal and compliant. If there are individual external personnel participating, the share subscription price, pricing basis, and source of funds should be explained, and a clear conclusive opinion should be issued on whether participation in the employee stock ownership plan is legal and compliant and whether there is any tunneling of benefits; (2) provide a detailed explanation of the relevant situation of the option incentive plan, the pricing basis and fairness of the exercise price, and lawyers should fully verify whether reserved rights and interests are set up and issue a clear conclusive opinion on whether the option incentive plan is legal and compliant.
3. Please provide a list explaining whether the business scope and actual business of your company and its subsidiaries involve restricted or prohibited areas in the "Special Administrative Measures for Foreign Investment Access (Negative List)" (2024 Edition), and whether they continue to comply with foreign investment access policy requirements before and after this issuance and listing and the "Full Circulation."
4. Please describe in plain and easy-to-understand language the core patented technologies, application scenarios, and specific functions of your company's main products or services. Several controlled subsidiaries of the issuer have no actual external business operations; please explain the reasons and specific circumstances.
5. Please supplement the explanation of whether the shares held by shareholders proposed to participate in the "Full Circulation" this time are subject to pledges, freezing, or other rights defects.
The prospectus shows that Purple X Technology is an e-commerce technology company dedicated to combining industry expertise with AI technology to revolutionize e-commerce operation models. As a leading e-commerce software provider in China, the company offers a comprehensive suite of e-commerce native software products designed to meet the core operational needs of e-commerce sellers. Based on 2025 revenue, the company is the largest provider of e-commerce secure operation products. According to Frost & Sullivan, among the top four e-commerce software providers in the industry (by revenue), the company achieved the highest revenue growth rate and operating profit margin between 2023 and 2025. Leveraging the company's long-standing deep understanding of e-commerce scenarios and continuous investment in AI technology, the company launched its e-commerce AI application product matrix LinkFox in 2023. Under the LinkFox brand, the company has built a comprehensive AI agent matrix aimed at optimizing the core operational workflows of e-commerce store operations, bringing substantial AI-based productivity to sellers.