Pony Group Inc. (OTC: PNYG)

Pony Group Inc. was incorporated on January 7 2019 in the state of Delaware. The company is a United States holding company that conducts its operations through two wholly owned subsidiaries. The first subsidiary Pony Limousine Services Limited is a Hong Kong limited liability company formed on April 28 2016. The second subsidiary Universe Travel Culture & Technology Ltd. was incorporated in Shenzhen PRC on February 2 2019 as a wholly owned PRC subsidiary of the Hong Kong entity. Pony Group Inc. does not own any vehicles. Instead it provides airport pick up and drop off services and personal driver services for travelers moving between Guangdong Province and Hong Kong by acting as an intermediary that connects customers with local car fleet operators. The company currently employs four full time staff members split between technology and product development human resources and administration and customer service. Its principal office is located in Room 17 Flat B 17/F Tsipeng Industrial Building San Po Kong Kowloon Hong Kong with a monthly rent of HKD 3 700. The company reports that it holds all necessary business licenses and permits for its Hong Kong and PRC subsidiaries and does not possess any intellectual property.

The company generates revenue by charging a service fee to the car fleet providers that perform the booked transportation. Customers place orders through WeChat Tencent QQ email or telephone at any time of day. Upon receiving an order Pony Group requests a quote from its network of car fleet companies and forwards that quote to the customer. If the customer accepts the quote the booking is confirmed and the designated car fleet operator dispatches a driver to pick up the passenger at the agreed time and location. After the service is completed Pony Group receives a fee ranging from five to fifteen percent of the total transaction value. The firm markets its services primarily through word of mouth referrals and brand advertising. It also plans to promote its offerings via sponsored events and social networking sites such as Facebook Twitter and Instagram. The business experiences noticeable seasonality with demand peaking during the golden week holiday period in China and slowing down during the months of February through April. Pony Group does not maintain any commercial insurance coverage beyond participation in the mandatory government statutory social security plans including pension medical unemployment work injury maternity and housing provident fund contributions.

Pony Group Inc. competes in a fragmented ground transportation sector where it faces established rivals such as Shenzhen Anxun Automobile Rental Co. Ltd. The Motor Transport Company of Guangdong and Hong Kong Limited and China Comfort Shenzhen Travel Services Co. Ltd. The company asserts that it competes on the basis of price user experience brand technological innovation safety and reliability. Its strategic position in the Guangdong and Hong Kong corridor benefits from strong cross border travel demand which provides a steady flow of potential customers. However many competitors possess greater brand recognition longer operating histories larger marketing budgets and more substantial financial and operational resources. The company’s holding company structure subjects it to regulatory risks arising from both Hong Kong and PRC authorities including potential changes in foreign investment rules data protection laws cybersecurity requirements and anti monopoly enforcement. Pony Group Inc. is also exposed to United States legislative developments such as the Holding Foreign Companies Accountable Act and its amendment the Accelerating Holding Foreign Companies Accountable Act which could restrict the trading of its securities if its auditor is not inspected by the Public Company Accounting Oversight Board for the required consecutive years. As of the date of the filing the company’s auditor YCM CPA INC. is a United States based firm subject to regular PCAOB inspection and the firm has no intention of replacing it with a non US auditor. The firm reports that it has obtained all required licenses and permits for its Hong Kong and PRC operations and that it is not currently required to undergo a cybersecurity review because it does not process personal data for over one million users and its data handling does not involve national security matters.

The company serves primarily business companies travel agencies and societal associations that require transportation for employees clients or tour groups. These customers place orders for airport transfers city to city travel and event related transportation through the company’s WeChat QQ email and telephone channels. Pony Group does not disclose the specific names of its corporate clients in the filing. The customer base consists of institutional and corporate entities that value reliable flexible and on demand ground transportation solutions within the Guangdong and Hong Kong region. The firm’s revenue is concentrated among these types of customers rather than individual retail passengers.