Hunan Lujun Law Firm
Regarding the Legal Opinion on the Signing of a Major Contract by a Wholly-Owned Subsidiary of Xingyun Technology Co., Ltd.
(2026) Luxun Law Opinion No. 005
To: Xingyun Technology Co., Ltd.
Hunan Lujun Law Firm (hereinafter referred to as "the Firm") has been entrusted by Xingyun Technology Co., Ltd. (hereinafter referred to as "the Company" or "Xingyun Technology") to act as special legal counsel. Based on the laws, regulations, departmental rules, and other normative documents of the People's Republic of China, including the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China," the "Shenzhen Stock Exchange ChiNext Stock Listing Rules," and the "Shenzhen Stock Exchange Listed Company Self-Regulatory Supervision Guide No. 2 - Standardized Operation of ChiNext Listed Companies," as well as the relevant provisions of the Articles of Association of Xingyun Technology Co., Ltd., and in accordance with the business standards, ethical norms, and diligent and conscientious spirit universally recognized in the legal profession, this legal opinion is issued regarding the legality, authenticity, and effectiveness of the "Computing Power Service Agreement" signed by the Company's wholly-owned subsidiary, Shenzhen Xingyun Holdings Co., Ltd. (hereinafter referred to as "Shenzhen Xingyun"), and VB Customer.
Special Statement of the Firm
I. The Firm has prepared this Legal Opinion strictly in accordance with the laws, administrative regulations, departmental rules, and other normative documents of the People's Republic of China that are currently in effect, based on the acts and facts that have occurred or existed prior to the issuance date of this Legal Opinion, and that existed or occurred at the time of such acts and facts.