Legal Opinion on the Adjustment of Stock Option Exercise Price and Quantity for Focus Technology Co., Ltd.'s 2025 Stock Option Incentive Plan
To: Focus Technology Co., Ltd.
Beijing Tianchi Juntai Law Firm Shanghai Branch (hereinafter referred to as "this firm") has been entrusted by Focus Technology Co., Ltd. (hereinafter referred to as "Focus Technology" or "the Company") to act as special legal counsel regarding matters related to the Company's 2025 Stock Option Incentive Plan (hereinafter referred to as "this Incentive Plan"). On April 29, 2025, we issued the "Legal Opinion on the Draft of Focus Technology Co., Ltd.'s 2025 Stock Option Incentive Plan," and on October 24, 2025, we issued the "Legal Opinion on the Adjustment of the Exercise Price of Focus Technology Co., Ltd.'s 2025 Stock Option Incentive Plan." Due to Focus Technology's intention to adjust the exercise price and quantity of the 2025 Stock Option Incentive Plan, our lawyers have issued this legal opinion based on the relevant laws and regulations, including the Company Law of the People's Republic of China (hereinafter referred to as "the Company Law"), the Securities Law of the People's Republic of China (hereinafter referred to as "the Securities Law"), the Management Measures for Equity Incentives of Listed Companies issued by the China Securities Regulatory Commission (hereinafter referred to as "the Management Measures"), the Listing Rules of the Shenzhen Stock Exchange (hereinafter referred to as "the Listing Rules"), and the Self-Regulatory Guidelines for Listed Companies of the Shenzhen Stock Exchange No. 1 - Business Handling (hereinafter referred to as "the Self-Regulatory Guidelines"), as well as the relevant provisions of the Articles of Association of Focus Technology Co., Ltd. (hereinafter referred to as "the Articles of Association"). In accordance with the requirements of the Measures for the Administration of Securities Legal Services by Law Firms (hereinafter referred to as "the Practice Measures") and the Trial Implementation Rules for Securities Legal Services by Law Firms (hereinafter referred to as "the Practice Rules"), and based on the recognized business standards, ethical norms, and diligent spirit of the legal profession, we hereby issue this legal opinion.
Declaration
In issuing this legal opinion, our firm and the lawyers make the following declarations: