To The Moon

October 23, 2026 — The China Securities Regulatory Commission (CSRC) published supplementary material requirements for overseas listing filings for the period of October 19 to October 23, 2026, according to reports.

The CSRC has requested that Baseline Technology provide supplementary explanations on whether any shareholding on behalf of others (nominee shareholding) existed in its historical evolution, and issue a conclusive opinion on whether the company's establishment and successive equity changes were lawful and compliant.

According to a disclosure by the Hong Kong Stock Exchange on April 29, Baseline Technology submitted an IPO application to the HKEX, with Guotai Junan International as the sole sponsor.

In addition, the CSRC requested Baseline Technology to supplement explanations on the following matters, with lawyers required to verify and issue clear legal opinions:

To explain (1) whether the industrial and commercial registration changes of the partners of Jiliu Xiliu and Jiliu Xize have been completed, and whether there are any changes compared with the filing materials; (2) whether Xinglian Dingsen and Hangzhou Guanghe are registered private equity funds, and if not, to conduct penetration verification in accordance with the requirements of the "Regulatory Rules Application Guidelines — Overseas Issuance and Listing No. 2" (hereinafter referred to as the "Regulatory Guidelines No. 2"); (3) whether Hangzhou Guanghe and Suzhou Guangyue are controlled by the same entity, their shareholding ratios should be calculated on a consolidated basis, and to conduct penetration verification of Suzhou Guangyue in accordance with the standards for shareholders holding 5% or more.

To explain (1) in accordance with the requirements of the "Regulatory Guidelines No. 2," a complete verification of the situation of new shareholders within the most recent 12 months, including existing shareholders who newly acquired shares within the most recent 12 months, explaining transaction prices, pricing basis, and other circumstances on a transaction-by-transaction basis in chronological order; (2) if there are differences in the subscription prices of new shareholders, the reasons should be explained, and a clear conclusive opinion should be issued on whether the subscription prices are fair and reasonable and whether there is any tunneling of benefits.

To explain (1) in strict accordance with the "Regulatory Guidelines No. 2," whether the new shareholders Yuanchuang Weilai Fund and Huahai Jinpu involve circumstances where entities prohibited by laws and regulations from holding shares directly or indirectly hold shares of the issuer; (2) whether the relationship between new shareholder Shanghai Guofang and others and the sponsor Guotai Junan Financing Limited affects the independence of the intermediary institution, and whether it complies with the rules of the listing jurisdiction.

To explain (1) the reasons and necessity for the issuer to establish multiple employee shareholding platforms, and whether the incentive prices and conditions of each platform are consistent; (2) whether Jiao Fangzheng, having served for less than one year, meets the conditions for equity incentive grants, and whether the retention of incentive shares complies with the articles of association or agreements of the employee stock ownership plan; (3) to issue a clear conclusive opinion on whether the equity incentive is lawful and compliant, whether the price is fair, and whether there is any tunneling of benefits.

To explain (1) whether the shares held by shareholders proposed to participate in the "full circulation" this time are subject to pledge, freezing, or other defects in rights; (2) to explain the progress of the state-owned shareholder Karamay Chengfa Fund in handling the state-owned share identification, and if it is in progress, to undertake to complete it before this issuance and listing.

The upper limit of the issuance quantity in the filing materials and the prospectus should remain consistent. If there are inconsistencies, please provide a revised filing report or prospectus. If the prospectus involves an increase in the number of shares issued this time and the scale of funds raised, please also update the use of proceeds plan.

The prospectus shows that Baseline Technology is China's largest independent AI computing cluster provider, leading disruptive innovation in the AI infrastructure field. The rapid evolution of AI technology has driven growing social demand for high-performance AI infrastructure. The bottleneck in designing and delivering high-performance AI infrastructure lies not only in high-performance computing and network chips themselves, but also in whether network systems, orchestration and scheduling mechanisms, and parallel computing technologies can turn thousands of processors into a high-performance supercomputer.