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Zhong Lun Law Firm
Supplementary Legal Opinion (IV) on Chongqing Xinlv Technology Co., Ltd.'s Issuance of Shares for Asset Acquisition and Raising of Supporting Funds and Related Party Transactions
June 2026
Table of Contents
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"1. Regarding the industrial logic of this transaction" in the "Audit Inquiry Letter" 6
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"2. Regarding the plan for this transaction" in the "Audit Inquiry Letter" 15
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"3. Regarding the operating performance and financial status of the target assets" in the "Audit Inquiry Letter" 53
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"5. Regarding the historical evolution and shareholders of the target assets" in the "Audit Inquiry Letter" 66
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"6. Regarding the compliance of production and operation and relevant qualifications of the target assets" in the "Audit Inquiry Letter" 113
To: Chongqing Xinlv Technology Co., Ltd.
Zhong Lun Law Firm (hereinafter referred to as "this Firm") was engaged by Chongqing Xinlv Technology Co., Ltd. (hereinafter referred to as "Xinlv Technology," "the Company," or "the Listed Company") to serve as the special legal counsel for the Listed Company's issuance of shares to purchase assets and raising of supporting funds and related party transactions (hereinafter referred to as "this Transaction").
In accordance with the "Company Law of the People's Republic of China," the "Securities Law of the People's Republic of China," the "Administrative Measures for Major Asset Restructuring of Listed Companies," the "Administrative Measures for the Registration of Securities Issuance by Listed Companies," the "Continuous Supervision Measures for Listed Companies on the ChiNext Market (Trial)," the "Shenzhen Stock Exchange Rules for the Review of Major Asset Restructuring of Listed Companies," the "Guidelines No. 26 for the Content and Format of Information Disclosure by Companies Offering Securities to the Public—Major Asset Restructuring of Listed Companies," the "Shenzhen Stock Exchange ChiNext Market Stock Listing Rules," the "Administrative Measures for Law Firms Engaging in Securities Legal Business," the "Practice Rules for Law Firms Engaging in Securities Legal Business (Trial)," and other relevant laws, regulations, and normative documents of the China Securities Regulatory Commission (hereinafter referred to as "CSRC") and the Shenzhen Stock Exchange (hereinafter referred to as "SZSE"), this Firm's practicing lawyers have followed the business standards, ethical norms, and the spirit of diligence and responsibility generally accepted in the legal profession. We have previously issued the "Zhong Lun Law Firm's Legal Opinion on Chongqing Xinlv Technology Co., Ltd.'s Issuance of Shares for Asset Acquisition and Raising of Supporting Funds and Related Party Transactions" (hereinafter referred to as the "Legal Opinion"), the "Zhong Lun Law Firm's Supplementary Legal Opinion (I) on Chongqing Xinlv Technology Co., Ltd.'s Issuance of Shares for Asset Acquisition and Raising of Supporting Funds and Related Party Transactions" (hereinafter referred to as "Supplementary Legal Opinion (I)"), the "Zhong Lun Law Firm's Supplementary Legal Opinion (II) on Chongqing Xinlv Technology Co., Ltd.'s Issuance of Shares for Asset Acquisition and Raising of Supporting Funds and Related Party Transactions" (hereinafter referred to as "Supplementary Legal Opinion (II)"), and the "Zhong Lun Law Firm's Supplementary Legal Opinion (III) on Chongqing Xinlv Technology Co., Ltd.'s Issuance of Shares for Asset Acquisition and Raising of Supporting Funds and Related Party Transactions" (hereinafter referred to as "Supplementary Legal Opinion (III)"; the above documents are collectively referred to as the "Original Legal Opinions").