IPO News | Silicon-based Smart Proposes Hong Kong Stock Listing, China Securities Regulatory Commission Requests Additional Clarifications on the Details of the Pending Lawsuits and Recent Developments

The Zhitong Finance App learned that on December 26, the China Securities Regulatory Commission issued the “Requirements for Supplementary Materials for Overseas Issuance and Listing Filing (December 22, 2025 to December 26, 2025)”. The International Department of the China Securities Regulatory Commission announced supplementary material requirements for 19 companies. Among them, silicon-based intelligence was required to provide additional information on the specific circumstances and latest developments in pending lawsuits. According to the Hong Kong Stock Exchange's disclosure on October 31, Nanjing Silicon-based Intelligent Technology Group Co., Ltd. (Silicon-based Intelligence for short) submitted a listing application to the main board of the Hong Kong Stock Exchange, with CMB International and DBS Bank as co-sponsors.

The Securities Regulatory Commission requested Silicon-based Intelligence to further explain the following matters, and ask lawyers to check and issue clear legal opinions:

1. Please provide additional information on the progress of the company's state-owned shareholders in implementing state-owned assets management procedures such as the state-owned stock logo.

2. Regarding the business model: (1) Please explain the company's business model in easy-to-understand language; (2) Please explain the specific situation of the company's business involving the AI big model, application scenarios, specific functions, etc., and please issue a special explanation on this issue; (3) Please add that the business scope of the company and its subsidiaries includes artificial intelligence public data platforms; Internet data services; data processing and storage support services; big data services; data processing services; Internet information services; second-class value-added telecommunications services; film production services; market research (excluding external surveys); Radio and television program production and management; online culture management; market information consulting and investigation (not engaging in social surveys, social research, public opinion polls, public opinion polls); e-commerce (not engaging in value-added telecommunications or financial services); design and production of various types of advertisements; advertisement production; advertising design, agency; advertising; for-profit private training service agencies engaged in language ability, art, sports, technology, etc. training (other than subject and language cultural education and training for primary and secondary school students); the specific situation of performance agents, etc., whether they have actually carried out relevant business and specific operations Obtaining the necessary qualifications, whether it involves areas where foreign investment is restricted or prohibited, the maximum foreign stock ratio requirement, and whether it continues to meet the foreign investment entry requirements before and after the current listing and “full circulation”.

3. Please provide additional information: (1) the progress of the processing of the business change process for the company to register Chen Liping and Mao Liyan as Jiaxing Silicon Language Limited Partners; (2) the progress of the company's application for the extension of the high-tech enterprise certificate.

4. Please provide additional information on the company's previous capital increases and share transfer prices, the basis for pricing and the reasons for price differences, whether there are any abnormalities in consideration, and issue a concluding opinion on whether the establishment of the company and the successive equity changes are legal and compliant.

5. Please further explain the basis for the company to recognize Hangzhou Qianyu Intelligent Technology Co., Ltd., Hangzhou Silicon Aviation Digital Intelligence Life Technology Co., Ltd. as non-important participating companies rather than holding subsidiaries or important participating companies, and refer to the “Guidelines for the Application of Regulatory Rules - Overseas Issuance and Listing Class No. 2” to explain the company's basic situation, and check whether its business scope and business involve restricted or prohibited areas of foreign investment. Foreign stock ratio limits and whether it continues to comply with foreign investment before and after the current listing and “full circulation” Investment entry requirements.

6. Request the company to further explain the details and latest developments of the pending lawsuits, whether the relevant circumstances may have a significant adverse impact on the company's future operations, whether they may pose a material obstacle to this issuance, and whether the relevant pending lawsuits have been fully disclosed, and ask the company and lawyers to express clear opinions.

7. Please refer to the provisions of Article 8 of the “Trial Measures for the Administration of Overseas Issuance of Securities and Listing of Domestic Enterprises”, and request additional explanations on whether the company and all its subsidiaries are prohibited from issuing and listing overseas.

8. Please provide additional information on whether the shares held by shareholders who intend to participate in the “full circulation” have been pledged, frozen, or have other rights defects.

According to the prospectus, Silicon-based Intelligence is the largest provider of digital human intelligence in China, providing an excellent silicon-based workforce. According to Insight Consulting, in terms of revenue generated from providing digital human intelligence solutions in 2024, the company ranked first among all digital human intelligence providers in China, holding a 32.2% market share in the Chinese digital human intelligence industry, and is in a leading position. According to the same source, the company ranked second among global digital human intelligence providers in terms of generating revenue by providing digital human intelligence solutions in 2024.

Inspired by the widely proven L1 to L5 development paradigm in the autonomous driving industry, the company innovatively proposed a corresponding L1 to L5 development blueprint for China's digital human intelligence industry. This blueprint aims to promote the upgrading of content production models from human-led to AI-driven, and accelerate the transformation from AICopilot to AIAutoPilot. Similar to the concept of embodied intelligence in the robotics industry, the company created digital human intelligence in the field of AI through sound cloning, appearance cloning, and thought cloning technology.