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Hunan Lujun Law Firm's Legal Opinion on Xingyun Technology's Subsidiary Signing Cloud Computing Service Agreement

Xingyun Technology Co., Ltd.··6 pages

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Hunan Lujun Law Firm issues a legal opinion on a cloud computing service agreement signed by Xingyun Technology's subsidiary, Hainan Xingyun. The agreement, valued at RMB 5.508 billion over 5 years, is deemed a major contract. The firm confirms the parties' qualifications and the agreement's legality, compliance, and validity.

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Full Translation

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Hunan Lujun Law Firm

Address: Room 1308, Building 1, Gaofeng Yayuan, Xiangzhang Road 768, Yuhua District, Changsha City, Hunan Province

Postal Code: 410007

Legal Opinion on Xingyun Technology Co., Ltd. Controlled Subsidiary Hainan Xingyun Intelligent Computing Technology Co., Ltd. Signing the "Cloud Computing Service Agreement"

[2026] Lujun Law Opinion No. 01007

To: Xingyun Technology Co., Ltd.

Hunan Lujun Law Firm (hereinafter referred to as "the Firm") has been retained by Xingyun Technology Co., Ltd. (hereinafter referred to as "the Company" or "Xingyun Technology"). The Firm, acting as special legal counsel, has, in accordance with the "Civil Code of the People's Republic of China," the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China," the "Shenzhen Stock Exchange GEM Stock Listing Rules," the "Shenzhen Stock Exchange Listed Companies Self-Regulatory Management Guide No. 2 - Norms for Operation of GEM Listed Companies," and other relevant laws, regulations, business rules, and the "Articles of Association of Xingyun Technology Co., Ltd.," and in accordance with the business standards, ethical norms, and diligent and responsible spirit recognized by the legal profession, hereby issues this legal opinion regarding Hainan Xingyun Intelligent Computing Technology Co., Ltd., a controlled subsidiary of Xingyun Technology.

(hereinafter referred to as "Hainan Xingyun," a controlled subsidiary of the Company) and a VC customer (hereinafter referred to as "the Counterparty," whose full name and specific information are exempted from disclosure as required by regulations due to commercial secrets) signing the "Cloud Computing Service Agreement" and its supplementary agreement (hereinafter referred to as "the Agreement") regarding its legality, compliance, authenticity, and effectiveness.

Solemn 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 currently in effect in China, based on the acts and facts that have occurred or existed prior to the issuance date of this legal opinion, and based on the acts and facts that existed or occurred at the time of their occurrence or existence up to the issuance date of this legal opinion.

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