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United States securities and exchange commission logo
September 7, 2022
Dongning Wang
Chief Financial Officer
Chindata Group Holdings Ltd
No. 47 Laiguangying East Road
Chaoyang District, Beijing, 100012
The People's Republic of China
Re: Chindata Group
Holdings Ltd
Form 20-F for the
Fiscal Year Ended December 31, 2021
Filed April 29,
2022
File No. 001-39556
Dear Mr. Wang:
We have reviewed your August 19, 2022 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
August 8, 2022 letter.
Form 20-F for the Fiscal Year Ended December 31, 2021
Introduction, page 1
1. We note your response
to prior comment 1. Please revise to include your definition of
China or PRC in the
Introduction where you define all other terms and ensure that it is
clear such definition
includes Hong Kong and Macau. Also, clarify, if true, that the only
time "China" and "PRC"
does not include Hong Kong or Macau is when you reference
specific laws and
regulations adopted by the PRC.
Dongning Wang
FirstName LastNameDongning
Chindata Group Holdings Ltd Wang
Comapany 7,
September NameChindata
2022 Group Holdings Ltd
September
Page 2 7, 2022 Page 2
FirstName LastName
Item 3. Key Information, page 3
2. We note your revised disclosures in response to prior comment 3.
Please further revise to
remove the reference to 100% as it relates to Sitan Beijing and Hebei
Qinshu as this
appears to imply that the WFOE has equity ownership over the VIE.
Financial Information Related to Our VIEs, page 8
3. Please explain why the amounts disclosed in your proposed revised
disclosures to prior
comment 5 do not agree to the amounts disclosed in the revised
consolidating worksheets
for "intercompany costs and expenses."
4. We note your revised presentation in response to prior comment 8.
Please further revise
to present a separate column for the WFOEs that are the primary
beneficiaries, which
appear to be Suzhou Stack Data Technology Investment Company Limited
and Hebei
Stack Data Technology Investment Company Limited and their respective
subsidiaries.
Also, tell us what the "other subsidiaries" column represents and how
these subsidiaries
differ from the other subsidiaries included in the WFOE column in your
proposed revised
disclosures. If this column relates to subsidiaries of the WFOE or the
Parent, please move
the placement of the column in the worksheet so that it is clear to
which entity the
subsidiaries belong.
5. Please revise your consolidating balance sheets data to present
investments in subsidiaries
separately from contractual interest in VIEs. Also tell us and revise
to clarify what the
amount in the contractual interest in the VIEs represents, as the
current line item
description appears to imply an equity relationship exists between the
primary beneficiary
and the VIE.
6. Your revised consolidating statements of operations data includes a
line item called
"Share of income of subsidiaries and contractual interest in the
VIEs," which appears to
imply an equity relationship exists between the WFOE and the VIE.
Please revise further
to present contractual interest in the VIEs on a separate line. Also,
tell us and revise to
clarify what the contractual interest in VIEs represents. To the
extent this relates to
amounts paid by the VIE pursuant to contractual arrangements, tell us
how this differs
from the inter-company revenue and inter-company cost and expenses
already disclosed
and revise as necessary.
Item 5. Operating and Financial Review and Prospects
Critical Accounting Estimates, page 106
7. We note your proposed disclosure in response to prior comment 15. It
is unclear whether
you intend to continue to include the other policies previously
disclosed starting on page
106. To the extent that you do, please revise such disclosures to
explain why each critical
accounting estimate is subject to uncertainty and, to the extent the
information is material
and reasonably available, how much each estimate and/or assumption has
changed over a
Dongning Wang
Chindata Group Holdings Ltd
September 7, 2022
Page 3
relevant period, and the sensitivity of the reported amounts to the
material methods,
assumptions and estimates underlying its calculation and include your
proposed
disclosures in your response. Refer to Item 5.E. of Form 20-F.
You may contact Melissa Kindelan, Staff Accountant, at (202) 551-3564 or
Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499, with any questions.
FirstName LastNameDongning Wang Sincerely,
Comapany NameChindata Group Holdings Ltd
Division of
Corporation Finance
September 7, 2022 Page 3 Office of
Technology
FirstName LastName