Response of Dark Horse Technology Group Co., Ltd. to the Second Round of Audit Inquiry Letter from the Shenzhen Stock Exchange Regarding the Issuance of Shares and Cash Payment for Asset Acquisition and Raising of Supporting Funds (Revised Draft)

Shenzhen Stock Exchange:

We have received the "Second Round of Audit Inquiry Letter Regarding the Application of Dark Horse Technology Group Co., Ltd. for Issuance of Shares and Cash Payment for Asset Acquisition and Raising of Supporting Funds" (Audit Letter [2025] No. 030015) (hereinafter referred to as the "Second Round Inquiry Letter") issued by your exchange on November 11, 2025. Dark Horse Technology Group Co., Ltd. (hereinafter referred to as "Dark Horse," the "Listed Company," or the "Company"), together with relevant intermediary agencies, has conducted a thorough verification and implementation of the issues listed in the Second Round Inquiry Letter and has made corresponding revisions and supplementary disclosures in the "Report on the Issuance of Shares and Cash Payment for Asset Acquisition and Raising of Supporting Funds of Dark Horse Technology Group Co., Ltd. (Draft)" (hereinafter referred to as the "Restructuring Report"). We hereby provide the response as follows for your review.

Notes:

1. Unless otherwise specified, the definitions of abbreviations or terms in this response are the same as those in the "Restructuring Report."

2. In this response, any discrepancies between the totals and the sums of individual items are due to rounding.

Question 1. Regarding the Compliance of the Core Business

The application documents and response documents show: (1) The listed company intends to acquire 100% equity of Beijing Banxintong Technology Co., Ltd. (hereinafter referred to as Banxintong or the Target Asset). (2) The industry regulatory authorities for the target asset mainly include the Ministry of Industry and Information Technology, the Office of the Central Cyberspace Affairs Commission and its subordinate agencies, the Publicity Department of the CPC Central Committee, the National Copyright Administration, and the National Intellectual Property Administration, with relevant industry associations including the Telecommunications Terminal Industry Association and the Copyright Society of China. (3) The target company's electronic copyright business is recognized by mainstream domestic application distribution platforms and complies with industry standards and specifications. (4) The target asset's electronic copyright certification business mainly conducts formal reviews and does not involve substantive verification of whether an APP is independently developed or whether there is any infringement of others' software copyrights through copying or modification. (5) Due to the lack of a comparable price system for the same business in the market, the target asset determines its pricing standards by referring to existing business pricing and historical development investment. (6) According to public records, in 2023, Shanghai Qimao Culture Media Co., Ltd. (hereinafter referred to as Qimao Media) filed a lawsuit against Xi'an Naika Enterprise Consulting Co., Ltd. due to other unfair competition disputes. To clarify the facts, the Shanghai Songjiang District People's Court legally added the target asset as a third party to the litigation, and Qimao Media subsequently applied to withdraw the lawsuit.