Hunan Lujun Law Firm
Legal Opinion on the Signing of a Major Contract by Xingyun Technology Co., Ltd.
[2026] Lujun Fa Yi Zi No. 01007
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") as its special legal counsel. The Firm hereby issues this Legal Opinion on the legality, authenticity, and effectiveness of the "Computing Power Service Contract" signed by the Company and a state-owned enterprise supplier (hereinafter referred to as the "SA Supplier" for short) in accordance with 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 Company Self-Regulatory Guidance No. 2 - Standardized 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 universally recognized business standards, ethical norms, and diligent and responsible spirit of the legal profession.
Special Statement of the Firm
I. The Firm has strictly prepared this Legal Opinion in accordance with the laws, administrative regulations, departmental rules, and other normative documents of the People's Republic of China that were effective at the time of the occurrence or existence of the acts and facts that have occurred or existed prior to the issuance date of this Legal Opinion, and that are effective during the period from the occurrence or existence of the aforementioned acts and facts to the issuance date of this Legal Opinion.