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United States securities and exchange commission logo
June 29, 2021
Richard Jian Liu
Chief Financial Officer
EHang Holdings Ltd
Building C, Yixiang Technology Park
No. 72 Nanxiang Second Road, Huangpu District
Guangzhou, 510700
People' Republic of China
Re: EHang Holdings Ltd
Form 20-F for the
Year Ended December 31, 2020
Filed June 15, 2021
File No. 001-39151
Dear Mr. Liu:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 20-F for the Year Ended December 31, 2020
Exhibits 12.1 and 12.2, page 1
1. We noted that the
certifications filed as Exhibits 12.1 and 12.2 exclude the introductory
language regarding
internal control over financial reporting in the fourth paragraph. Please
amend the filing to
provide revised certifications that include the required information.
You may file an
abbreviated amendment that is limited to the cover page, explanatory
note, signature page
and paragraphs 1, 2, 4 and 5 of the certifications. Refer to Exchange
Act Rule 13a-14(a) and
Item 601(b)(31) of Regulation S-K.
Richard Jian Liu
FirstName LastNameRichard Jian Liu
EHang Holdings Ltd
Comapany
June NameEHang Holdings Ltd
29, 2021
June 29,
Page 2 2021 Page 2
FirstName LastName
Notes to the Consolidated Financial Statements
2. Summary of Significant Accounting Policies
(ad) Segment Reporting, page F-31
2. We note your disclosure that you have one reportable segment. Tell us
how you assessed
whether each of the commercial solutions (i.e., air mobility
solutions, smart city
management solutions and aerial media solutions) is an operating
segment as defined in
ASC 280-10-50-1. If you have determined that the commercial solutions
are operating
segments that can be aggregated, demonstrate how you determined that
aggregation
complies with the requirements of ASC 280-10-50-11, including similar
economic
characteristics. In this regard, we note from your disclosure on page
89 that Air Mobility
Solutions had a higher gross profit margin. If you have determined
that your commercial
solutions are not operating segments, explain how you made that
determination.
5. Accounts Receivables, Net, page F-36
3. Please tell us how you determined the appropriate allowance amount at
December 31,
2020, including your consideration of ASC 310-10-35-7 through 35-11
when establishing
your allowance of doubtful accounts. Provide us with and disclose an
aging of your
accounts receivable as of December 31, 2020, detailing the total
amounts outstanding at
the balance sheet date by categories of time, such as over 30 days,
over 90 days, over six
months, over one year, over two years, etc. For each category, show
the amount that has
been subsequently collected. Please also tell us and disclose the
nature and terms of the
payment commitment letters you signed with your customers and whether
they are legally
enforceable.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact SiSi Cheng at 202-551-5004 or John Cash at 202-551-3768
with any
questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing