Feiyinuo Technology Co., Ltd. (hereinafter referred to as "Feiyinuo"), which previously failed in its bid for a STAR Market listing, is now shifting to the ChiNext board to advance its IPO, planning to raise 872 million yuan. However, the latest news shows that because the financial information recorded in the application documents has passed its validity period and requires supplementary submission, the review status has been changed to suspended.

Feiyinuo is a domestic medical device enterprise founded by a former GE Healthcare team, focusing on the R&D, production, and sales of high-end digital color ultrasound diagnostic equipment, and has been recognized as a national-level specialized and sophisticated "little giant" enterprise. Its founding team established Feiyinuo before leaving GE, and therefore arranged equity proxy holdings. The company later became embroiled in a protracted trade secret lawsuit with GE.

But comparing Feiyinuo's two IPO prospectuses, the company appears to have attempted to conceal another equity proxy holding—due to the sensitive identity of the investor, a shareholder who "did not exist" in the previous version has been "exposed" in the latest ChiNext version. This also implicates that Feiyinuo may have lied during its previous IPO.

The Shareholder Who "Did Not Exist" in the Prospectus

As early as December 30, 2022, Feiyinuo's STAR Market IPO was accepted by the Shanghai Stock Exchange. In the application draft disclosed at that time, an individual named Xu Xiuzhen held a 6.6738% stake, ranking as a shareholder holding more than 5% of the company. Regarding information about "Xu Xiuzhen," Feiyinuo only disclosed that she was born in 1937, meaning she was already 85 years old at the time, with no further information provided.

That prospectus stated, "There have been instances of equity proxy holdings in the company's historical evolution. As of the date of signing this prospectus, the company's equity proxy holding situation has been resolved." However, the March 2026 ChiNext application draft revealed a proxy holding chain that had never appeared in the STAR Market version. At the same time, it can be clearly seen that the aforementioned statement—"As of the date of signing this prospectus, the company's equity proxy holding situation has been resolved"—is problematic.

The ChiNext prospectus shows that when Feiyinuo was established in 2010, an individual named Xu Huidong, "optimistic about the prospects of the ultrasound equipment market," decided to participate in the investment. Judging from the timing of Xu Huidong's investment, he was evidently very bullish on both the market prospects and Feiyinuo's founding team, which had not yet left GE. This is because Feiyinuo signed its articles of association and was established in March 2010, and Xu Huidong immediately invested 2.2 million yuan. According to the prospectus, because Xu Huidong was a shareholder and senior executive of the company where he worked, in order to avoid causing discussion among other shareholders of that company regarding his outside investment, he used his spouse Zhao Wen's name to hold 10% of Feiyinuo's equity on his behalf.

In August 2012, Zhao Wen transferred 9% of that to be held on behalf of Xu Huidong's mother, Xu Xiuzhen—the aforementioned octogenarian. In July 2016, Xu Xiuzhen received an additional 0.66% equity from Jingning Weining, held on behalf of Xu Huidong's classmate Xi Shangzhong. This means that at the time of the STAR Market prospectus (end of 2022), behind the 6.67% stake under Xu Xiuzhen's name, there were actually two "invisible shareholders" hidden: Xu Huidong and Xi Shangzhong. The STAR Market version made no mention of this at all, merely stating generically that it had been "resolved."

During the STAR Market application stage, proxy-held shares were a major matter that should be disclosed by law. The prospectus statement that "as of the date of signing this prospectus, the company's equity proxy holding situation has been resolved" is inconsistent with the facts. Does this constitute inaccurate information disclosure? Is there a suspicion of misleading statements?

State-Owned Enterprise Leader "Retreating on the Eve of Victory"?

The more interesting part comes next. Who exactly is this Xu Huidong, who was initially invisible and later disclosed as a "company executive afraid of being talked about for outside investment"? Public information points to a more specific identity—legal representative and chairman of Shanghai Suhao International Trade Co., Ltd. Shanghai Suhao International Trade Co., Ltd. is a company with state-owned capital participation. According to Tianyancha records, the state-owned Jiangsu Suhao International Group Co., Ltd. was for a long time the largest shareholder of Shanghai Suhao. As for Xu Huidong, he can be seen as the legal representative of Shanghai Suhao as early as 1996. On the webpage of the Nanjing University Shanghai Alumni Association, where Xu Huidong serves as president, he is introduced as "General Manager of Jiangsu Suhao International Group Co., Ltd. and Shanghai Suhao International Trade Co., Ltd."

According to the "Several Provisions on the Clean Practice of State-Owned Enterprise Leaders," state-owned enterprise leaders are not permitted to "personally engage in for-profit business activities and paid intermediary activities." The high degree of alignment in the timeline makes Xu Huidong's exit even more noteworthy. On June 27, 2023, Xu Huidong, as Xu Xiuzhen's guardian, signed share transfer agreements with Yuanhe Taihu, Suzhou Yuandu, and Jianfa No. 7, agreeing that Xu Xiuzhen would transfer all of her Feiyinuo shares to the aforementioned three institutions. This transfer involved 2,531,300 shares, 2,267,000 shares, and 607,500 shares, totaling 5,405,800 shares, with a total transfer price of approximately 133.5 million yuan. The prospectus explicitly records that "the share transfer payment has been paid in full."

On June 29, 2023, Feiyinuo formally submitted an application to the Shanghai Stock Exchange to withdraw its STAR Market IPO, and the Shanghai Stock Exchange made a termination review decision that same day. In other words, almost simultaneously before Feiyinuo withdrew its IPO application last time, Xu Huidong cleared his equity. If purely calculating economic benefits, the valuation of this transfer was not ideal. At the time of the June 2023 transfer, Feiyinuo's overall valuation was only about 2 billion yuan, whereas at the time of the STAR Market application, the company's target valuation was no less than 4.488 billion yuan. The valuation was cut in half. For an early investor who claimed to be optimistic about the company's prospects, clearing out on the eve of the company's IPO also defies common sense.

Was the exit of the "invisible" shareholder Xu Huidong a forced separation? Was the supplementary disclosure of this proxy holding in the ChiNext application a proactive correction, or was it because the application could not pass without disclosure? The prospectus does not answer this. And that Xu Huidong, who "wanted to avoid discussion among other shareholders of the company where he worked," has already exited with real money in hand.