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United States securities and exchange commission logo
October 3, 2023
Qiaoling Lu
Chief Executive Officer
Sentage Holdings Inc.
501, Platinum Tower
233 Taicang Road
HuangPu, Shanghai City 200001
People's Republic of China
Re: Sentage Holdings
Inc.
Annual Report on
Form 20-F for Fiscal Year Ended December 31, 2022
Response dated
September 15, 2023
File No. 001-40580
Dear Qiaoling Lu:
We have reviewed your September 15, 2023 response to our comment
letter and have the
following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our August 31,
2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Item 5. Operating and Financial Review and Prospects
Operating expenses, page 97
1. Please refer to prior
comment 12. We note that your proposed disclosure in your response
is nearly the same as
the existing disclosure on page 97 of your Form 20-F for the year
ended December 31,
2022. Please revise future filings, and provide us with a draft of your
proposed disclosure, to
disclose the individual material components which make up your
total selling, general
and administrative expenses for the reporting periods presented. For
example, your
disclosure should:
identify and
quantify each individually significant component of selling, general and
administrative
expenses;
Qiaoling Lu
Sentage Holdings Inc.
October 3, 2023
Page 2
quantify the change in each respective component during each
period; and
discuss the reasons for the increases or decreases in the
specific dollar amounts for
each of the components identified.
Consolidated Financial Statements
Note 2 Summary of significant accounting policies
Convenience translation, page F-13
2. Please refer to prior comment 16. We note in your proposed disclosure
that you perform
translation for income and expense items using the average exchange
rate for the next
financial year. Please tell us how this policy complies with the
guidance in ASC 830 or,
if accurate, revise your disclosure to clarify that your translation
of income and expense
items uses an average exchange rate for the periods presented in the
consolidated financial
statements. Refer to ASC 830-10-55-10 and 55-11.
General
3. We note that you responded to prior comments 1, 2, 4 and 7 with a
statement that you will
make the requested changes in future filings. Provide us with an
example of the
responsive disclosure to each comment in your response to this comment
letter.
Please contact Katharine Garrett at 202-551-2332 or William Schroeder
at 202-551-3294
if you have questions regarding comments on the financial statements and
related matters. Please
contact Aisha Adegbuyi at 202-551-8754 or Christian Windsor at 202-551-3419
with any other
questions.
FirstName LastNameQiaoling Lu Sincerely,
Comapany NameSentage Holdings Inc.
Division of
Corporation Finance
October 3, 2023 Page 2 Office of
Finance
FirstName LastName