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United States securities and exchange commission logo
July 28, 2023
Jun Wang
Chief Financial Officer
iQIYI, Inc.
No. 21, North Road of Workers' Stadium
Chaoyang District, Beijing 100027
People s Republic of China
Re: iQIYI, Inc.
Form 20-F for
Fiscal Year Ended December 31, 2022
Response Dated June
20, 2023
File No. 001-38431
Dear Jun Wang:
We have reviewed your June 20, 2023 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
May 22, 2023 letter.
Response Dated June 20, 2023
Introduction, page 1
1. We note your proposed
amended disclosure in response to comment 1 and we reissue in
part. Please revise to
include a definition of China and the PRC.
Item 3. Key Information, page 3
2. We note your proposed
amended disclosure in response to comment 4 and reissue in part.
We note that you have
provided cross-refences to your risk factors. Please revise to also
provide
cross-references to your summary risk factors.
Jun Wang
FirstName
iQIYI, Inc. LastNameJun Wang
Comapany
July NameiQIYI, Inc.
28, 2023
July 28,
Page 2 2023 Page 2
FirstName LastName
3. We note your response to comment 7 and we reissue in part. Please
provide your
proposed revised structure chart and the include the summaries of the
contractual
arrangements in Item 3.
4. We note your response to comment 8 and reissue in part. We note the
proposed disclosure
still maintains that you receive the economic benefits of the variable
interest entities. Any
references to control or benefits that accrue to you because of the
VIEs should be limited
to a clear description of the conditions you have satisfied for
consolidation of the VIEs
under U.S. GAAP. Please revise.
5. We note your response to comment 9, including that you undertake to
provide the specific
risk factor cross reference (with title and page number) to each risk
disclosed in Risks
Related to Our Corporate Structure and Risks Related to Doing
Business in Mainland
China. It appears that you have not provided proposed disclosure
for each of the
summary risk factors in "Risks Related to Doing Business in Mainland
China." Please
provide such proposed disclosure.
Please contact Rucha Pandit at (202) 551-6022 or Cara Wirth at (202)
551-7127 with any
questions.
Sincerely,
Division of
Corporation Finance
Office of Trade
& Services
cc: Haiping Li