Exhibit 15.4
ATA Creativity Global
c/o 1/F East Gate, Building No. 2, Jian Wai Soho,
No. 39 Dong San Huan Zhong Road,
Chao Yang District, Beijing 100022, China
April 12, 2023
By EDGAR
Securities and Exchange Commission
Division of Corporate Finance
100 F. Street, N.E.
Washington, DC 20549
| Re: | ATA Creativity Global | |
| Submission under the Item 16I(a) of Form 20-F |
Ladies and Gentlemen:
ATA Creativity Global (the “Company”) is submitting the following information pursuant to Item 16I(a) of Form 20-F.
The Company was identified by the Securities and Exchange Commission pursuant to Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C. 7214(i)(2)(A)) as having retained, for the preparation of the audit report on its financial statements included in its annual report on Form 20–F for the fiscal year ended December 31, 2021, KPMG Huazhen LLP, a registered public accounting firm that is located in mainland China and that the United States Public Company Accounting Oversight Board (the “PCAOB”) had then determined it was unable to inspect or investigate completely because of a position taken by one or more authorities in mainland China, which determination was vacated by the PCAOB on December 15, 2022.
To the Company’s best knowledge, and based on an examination of the Company’s register of members and public filings made by its shareholders, particularly the Schedule 13Ds and Schedule 13Gs, the Company herby respectfully submits that it is not owned or controlled by any governmental entity in mainland China as of the date of this submission. In addition, to the Company’s best knowledge, as of the date of this submission, the Company is not aware of any governmental entity in mainland China that is in possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of the Company, whether through the ownership of voting securities, by contract, or otherwise.
Should any member of the Staff have any questions or comments regarding the Company’s submission set forth above, please do not hesitate to contact me by phone at (8610) 65181133-5518, or you may contact our outside legal counsel, Mr. Ning Zhang, Morgan, Lewis & Bockius LLP, at (852) 3551-8690.
* * *
| Very truly yours, |
| /s/ Ruobai Sima |
| Name: Ruobai Sima |
| Title: Chief Financial Officer |
| cc: |
Mr. Ning Zhang, Morgan, Lewis & Bockius LLP |