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AirNet Technology Inc.

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FY2018 Annual Report · AirNet Technology Inc.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington D.C. 20549

FORM 20-F

☐ REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934

☒ ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

OR

For the fiscal year ended December 31, 2018

OR

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

OR

☐ SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

Date of event requiring this shell company report ____________________

For the transition period from __________ to __________.

Commission file number: 001-33765

AIRMEDIA GROUP INC.
(Exact name of Registrant as specified in its charter)

Not Applicable
(Translation of Registrant’s name into English)

Cayman Islands
(Jurisdiction of incorporation or organization)

15/F, Sky Plaza
No. 46 Dongzhimenwai Street
Dongcheng District, Beijing 100027
The People’s Republic of China

(Address of principal executive offices)

Xin Li
Chief Financial Officer 
AirMedia Group Inc.
15/F, Sky Plaza
No. 46 Dongzhimenwai Street
Dongcheng District, Beijing 10027
The People’s Republic of China
Phone:+86 10 8460 8181
Email: lixin@ihangmei.com

(Name, Telephone, E-mail and/or Facsimile number and Address of Company Contact Person)

Securities registered or to be registered pursuant to Section 12(b) of the Act:

Title of each class
Ordinary shares, par value $0.001 per share*
American Depositary Shares, each representing
ten ordinary shares

Name of each exchange on which registered
The Nasdaq Stock Market LLC
(The Nasdaq Capital Market)

* Not  for  trading,  but  only  in  connection  with  the  listing  on  the  Nasdaq  Global  Market  of  American  depositary  shares,  each  representing  ten  ordinary

shares.

Securities registered or to be registered pursuant to Section 12(g) of the Act.

Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act.

None
(Title of Class)

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
None
(Title of Class)

Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period covered by the annual report:
As of December 31, 2018, 125,664,777  ordinary shares, par value $0.001 per share, were outstanding.

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

Yes ☐

No ☒

If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or 15(d) of the
Securities Exchange Act of 1934.

Yes ☐

No ☒

Note – Checking the box above will not relieve any registrant required to file reports pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934
from their obligations under those Sections.

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934
during  the  preceding  12  months  (or  for  such  shorter  period  that  the  registrant  was  required  to  file  such  reports),  and  (2)  has  been  subject  to  such  filing
requirements for the past 90 days.

Yes ☒

No ☐

Indicate  by  check  mark  whether  the  registrant  has  submitted  electronically  every  Interactive  Data  File  required  to  be  submitted  pursuant  to  Rule  405  of
Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).

Yes ☒

No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or an emerging growth company. See the
definitions of “large accelerated filer,” “accelerated filer,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large Accelerated Filer ☐

Non-Accelerated Filer ☒

Accelerated Filer ☐

Emerging growth company ☐

If an emerging growth company that prepare its financial statements in accordance with U.S. GAAP, indicate by check mark if the registrant has elected not to
use the extended transition period for complying with any new or revised financial accounting standards† provided pursuant to Section 13(a) of the Exchange
Act. ☐

† The  term  “new  or  revised  financial  accounting  standard”  refers  to  any  update  issued  by  the  Financial  Accounting  Standards  Board  to  its  Accounting
Standards Codification after April 5, 2012.

Indicate by check mark which basis of accounting the registrant has used to prepare the financial statements included in this filing:

U.S. GAAP ☒

International Financial Reporting Standards as issued by the International Accounting Standards Board ☐

Other ☐

If “Other” has been checked in response to the previous question, indicate by check mark which financial statement item the registrant has elected to follow.

☐ Item 17

☐ Item 18

If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).

Yes ☐

No ☒

(APPLICABLE ONLY TO ISSUERS INVOLVED IN BANKRUPTCY PROCEEDINGS DURING THE PAST FIVE YEARS)

Indicate by check mark whether the registrant has filed all documents and reports required to be filed by Sections 12, 13 or 15(d) of the Securities Exchange
Act of 1934 subsequent to the distribution of securities under a plan confirmed by a court.

Yes ☐

No ☐

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

Annual Report on Form 20-F

TABLE OF CONTENTS

PART I

PART II

ITEM 1.
ITEM 2.
ITEM 3.
ITEM 4.
ITEM 4A.
ITEM 5.
ITEM 6.
ITEM 7.
ITEM 8.
ITEM 9.
ITEM 10.
ITEM 11.
ITEM 12.

  IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS
  OFFER STATISTICS AND EXPECTED TIMETABLE
  KEY INFORMATION
  INFORMATION ON THE COMPANY
  UNRESOLVED STAFF COMMENTS
  OPERATING AND FINANCIAL REVIEW AND PROSPECTS
  DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES
  MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS
  FINANCIAL INFORMATION
  THE OFFER AND LISTING
  ADDITIONAL INFORMATION
  QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK
  DESCRIPTION OF SECURITIES OTHER THAN EQUITY SECURITIES

ITEM 13.
ITEM 14.
ITEM 15.
ITEM 16A.
ITEM 16B.
ITEM 16C.
ITEM 16D.
ITEM 16E.
ITEM 16F.
ITEM 16G.
ITEM 16H.

  DEFAULTS, DIVIDEND ARREARAGES AND DELINQUENCIES
  MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITIES HOLDERS AND USE OF PROCEEDS
  CONTROLS AND PROCEDURES
  AUDIT COMMITTEE FINANCIAL EXPERT
  CODE OF ETHICS
  PRINCIPAL ACCOUNTANT FEES AND SERVICES
  EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES
  PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS
  CHANGE IN REGISTRANT’S CERTIFYING ACCOUNTANT
  CORPORATE GOVERNANCE
  MINE SAFETY DISCLOSURE

PART III

ITEM 17.
ITEM 18.
ITEM 19.

  FINANCIAL STATEMENTS
  FINANCIAL STATEMENTS
  EXHIBITS

i

3

3
3
3
32
45
45
63
73
76
78
79
87
88

89

89
89
90
91
91
92
92
92
92
93
93

93

93
94
94

 
 
 
 
 
   
 
   
 
 
   
 
   
 
   
 
 
   
 
   
 
   
 
 
Except as otherwise indicated by the context, in this annual report:

INTRODUCTION

·

·

·

·

·

·

·

“ADS” refers to our American depositary shares, each of which represents ten ordinary shares;

“China” or “PRC” refers to the People’s Republic of China, excluding, for the purpose of this annual report only, Hong Kong, Macau and Taiwan;

“ordinary shares” refers to our ordinary shares, par value $0.001 per share;

“RMB” or “Renminbi” refers to the legal currency of China;

“U.S. dollars”, “$”, “US$” or “dollars” refers to the legal currency of the United States;

“VIEs” means our variable interest entities; and

“we”, “us”, “our”, the “Company” or “AirMedia” refers to the combined business of AirMedia Group Inc., its consolidated subsidiaries, its VIEs and
VIEs’ subsidiaries.

Although AirMedia does not directly or indirectly own any equity interests in its consolidated VIEs or their subsidiaries, AirMedia is the primary beneficiary
of and effectively controls these entities through a series of contractual arrangements with these entities and their record owners. We have consolidated the
financial  results  of  these  VIEs  and  their  subsidiaries  in  our  consolidated  financial  statements  in  accordance  with  the  Generally  Accepted  Accounting
Principles in the United States, or U.S. GAAP. See “Item 4. Information on the Company—C. Organizational Structure,” “Item 7. Major Shareholders and
Related  Party  Transactions—B.  Related  Party  Transactions”  and  “Item  3.  Key  Information—D.  Risk  Factors”  for  further  information  on  our  contractual
arrangements with these parties.

Our financial statements are expressed in U.S. dollars, which is our reporting currency. Certain Renminbi figures in this annual report are translated into U.S.
dollars solely for the reader’s convenience. Unless otherwise noted, all convenience translations from Renminbi to U.S. dollars in this annual report were
made at a rate of RMB6.8755 to $1.00, the exchange rate set forth in the H.10 statistical release of the Federal Reserve Board on December 31, 2018. We
make no representation that any Renminbi or U.S. dollar amounts could have been, or could be, converted into U.S. dollars or Renminbi, as the case may be,
at any particular rate, at the rate stated above, or at all.

FORWARD-LOOKING INFORMATION

This annual report on Form 20-F contains statements of a forward-looking nature. These statements are made under the “safe harbor provisions” of the U.S.
Private Securities Litigation Reform Act of 1995.

You can identify these forward-looking statements by words or phrases such as “may”, “will”, “expect”, “anticipate”, “aim”, “estimate”, “intend”, “plan”,
“believe”, “likely to” or other similar expressions. We have based these forward-looking statements largely on our current expectations and projections about
future  events  and  financial  trends  that  we  believe  may  affect  our  financial  condition,  results  of  operations,  business  strategy  and  financial  needs.  These
forward-looking statements include but are not limited to:

·

·

·

·

our growth strategies;

our future business development, results of operations and financial condition, including the products and services combining in-flight connectivity
and entertainment;

competition in the advertising industry and in particular, the travel advertising industry in China;

the expected growth in consumer spending, average income levels and advertising spending levels;

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
·

·

the growth of the air, train and long-haul bus travel sectors in China; and

PRC governmental policies relating to the advertising industry.

Also, forward-looking statements represent our estimates and assumptions only as of the date of this annual report. You should read this annual report and the
documents that we referred and filed as exhibits to this report in their entirety and with the understanding that our actual future results may be materially
different  from  what  we  expect.  Except  as  required  by  law,  we  assume  no  obligation  to  update  any  forward-looking  statements  publicly,  or  to  update  the
reasons  actual  results  could  differ  materially  from  those  anticipated  in  any  forward-looking  statements,  even  if  new  information  becomes  available  in  the
future.

2

 
 
 
 
 
 
 
ITEM 1.

IDENTITY OF DIRECTORS, SENIOR MANAGEMENT AND ADVISERS

Not applicable.

ITEM 2.

OFFER STATISTICS AND EXPECTED TIMETABLE

PART I

Not applicable.

ITEM 3.

KEY INFORMATION 

A.

Selected Financial Data

Selected Consolidated Financial Data

The following table represents our selected consolidated financial information. The selected consolidated statements of operations data for the years ended
December  31,  2016,  2017  and  2018  and  the  consolidated  balance  sheet  data  as  of  December  31,  2017  and  2018  have  been  derived  from  our  audited
consolidated  financial  statements,  which  are  included  in  this  annual  report.  The  selected  consolidated  statements  of  operations  data  for  the  years  ended
December  31,  2014  and  2015  and  the  selected  consolidated  balance  sheet  data  as  of  December  31,  2014,  2015  and  2016,  except  for  the  impact  of
retrospective adjustments for the deconsolidation of our media business in airports (excluding digital TV screens in airports and TV-attached digital frames)
and all billboard and LED media business outside of airports (excluding gas station media network and digital TV screens on airplanes), all of which have
been classified as discontinued operations, have been derived from our financial statements for the relevant periods, which are not included in this annual
report. Our consolidated financial statements are prepared and presented in accordance with U.S. GAAP.

These  selected  consolidated  financial  data  below  should  be  read  in  conjunction  with,  and  are  qualified  in  their  entirety  by  reference  to,  our  consolidated
financial  statements  and  related  notes  included  elsewhere  in  this  annual  report  and  “Item  5.  Operating  and  Financial  Review  and  Prospects”  below.  Our
historical results do not necessarily indicate results expected for any future periods.

  $

Consolidated Statements of Operations Data:
Revenues:
Air Travel Media Network
Gas Station Media Network
Other Media
Total revenues
Business tax and other sales tax
Net revenues
Cost of revenues
Gross loss
Operating expenses:
Selling and marketing
General and administrative
Impairment of fixed assets, prepaid equipment cost and

intangible assets

Total operating expenses
Loss from operations
Interest income (expense)
(Loss)/gain and impairment on long-term investments    
Other income, net
Loss before income taxes
Income tax (benefits) / expenses
Net loss from continuing operations
Net income from discontinued operations, net of tax
Net (loss)  income
Less: Net loss attributable to noncontrolling  interests
-Continuing operations
-Discontinued operations
Net (loss) income attributable to AirMedia Group

Inc.’s shareholders
-Continuing operations
-Discontinued operations
Weighted average shares outstanding used in

computing net (loss) income per ordinary share

-basic
Continuing operations
Discontinued operations
-diluted
Continuing operations

2014

Years Ended December 31,
2016
(In thousands of U.S. Dollars, except share, per share and per ADS data)

2017

2015

59,200    $
11,164     
5,583     
75,947     
(1,254)    
74,693     
(96,608)    
(21,915)    

(12,916)    
(20,620)    

—     
(33,536)    
(55,451)    
1,058     
(212)    
979     
(53,626)    
(1,512)    
(52,114)    
20,288     
(31,826)    
(6,131)    
(6,808)    
677     

(25,695)    
(45,306)    
19,611     

38,917    $
9,840     
2,109     
50,866     
(633)    
50,233     
(89,577)    
(39,344)    

(9,611)    
(27,102)    

—     
(36,713)    
(76,057)    
472     
2,352     
1,383     
(71,850)    
6,421     
(78,271)    
221,183     
142,912     
(6,735)    
(7,620)    
885     

149,647     
(70,651)    
220,298     

12,178    $
4,009     
410     
16,597     
(84)    
16,513     
(49,042)    
(32,529)    

(12,056)    
(44,401)    

(826)    
(57,283)    
(89,812)    
843     
(33)    
4,243     
(84,759)    
4,483     
(89,242)    
—     
(89,242)    
(23,617)    
(23,617)    
—     

(65,625)    
(65,625)    
—     

18,702     
4,093     
1,533     
24,328     
(569)    
23,759     
(58,967)    
(35,208)    

(12,747)    
(63,507)    

(67,342)    
(143,596)    
(178,804)    
2,645     
(2,603)    
214     
(178,548)    
633     
(179,181)    
—     
(179,181)    
(22,705)    
(22,705)    
—     

(156,476)    
(156,476)    
—     

2018

22,212 
413 
2,151 
24,776 
(230)
24,546 
(32,630)
(8,084)

(7,492)
(32,612)

(564)
(40,668)
(48,752)
(106)
(52,337)
7,926 
(93,269)
150 
(93,419)
— 
(93,419)
(3,322)
(3,322)
— 

(90,097)
(90,097)
— 

119,304,773     
119,304,773     

121,740,194     
121,740,194     

125,277,056     
—     

125,629,779     
—     

125,653,175 
— 

119,304,773     

121,740,194     

125,277,056     

125,629,779     

125,653,175 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
   
 
 
 
 
   
      
      
      
      
  
   
      
      
      
      
  
   
   
   
   
   
   
   
   
      
      
      
      
  
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
      
      
      
      
  
   
      
      
      
      
  
   
   
   
      
      
      
      
  
   
Discontinued operations
Net (loss) income attributable to AirMedia Group
Inc.’s shareholders per ordinary share—basic

Continuing operations
Discontinued operations
Net (loss) income attributable to AirMedia Group

Inc.’s shareholders per ordinary share—diluted    
  $

Continuing operations
Discontinued operations
Net (loss) income attributable to AirMedia Group

Inc.’s shareholders per ADS—basic(1)

Continuing operations
Discontinued operations
Net (loss) income attributable to AirMedia Group

Inc.’s shareholders per ADS—diluted(1)

Continuing operations
Discontinued operations

  $

  $

119,924,927     

129,372,158     

—     

—     

— 

  $

(0.38)   $
0.16     

(0.58)   $
1.81     

(0.52)   $
—     

(0.38)   $
0.16     

(0.58)   $
1.70     

(0.52)   $
—     

(1.25)    
—     

(1.25)    
—     

(3.80)   $
1.60     

(5.80)   $
18.1     

(5.24)   $
—     

(12.46)    
—     

(3.80)   $
1.60     

(5.80)   $
17.0     

(5.24)   $
—     

(12.46)    
—     

(0.72)
— 

(0.72)
— 

(7.17)
— 

(7.17)
— 

(1) Each  ADS  represents  ten  ordinary  shares  effective  on  April  11,  2019,  and  per  ADS  information  has  been  retrospectively  restated  for  all  periods

presented.

3

   
   
      
      
      
      
  
   
      
      
      
      
  
   
   
      
      
      
      
  
   
   
      
      
      
      
  
   
 
 
 
 
 
The following table presents a summary of our consolidated balance sheet data as of December 31, 2014, 2015, 2016, 2017 and 2018:

2014

2015

As of December 31,
2016
(In thousands of U.S. Dollars)

2017

2018

Balance Sheet Data:
Cash and cash equivalents
Total assets
Total liabilities
Total AirMedia Group Inc.’s shareholders’ equity
Noncontrolling interests
Total equity

B.

Capitalization and Indebtedness

Not applicable.

C.

Reasons for the Offer and Use of Proceeds

Not applicable.

  $

  $

60,117    $
395,597     
126,725     
248,736     
20,136     
268,872    $

86,960    $
531,601     
133,968     
386,568     
11,065     
397,633    $

117,547    $
381,190     
114,593     
268,737     
(2,140)    
266,597    $

15,355    $
225,002     
101,323     
147,649     
(23,970)    
123,679    $

15,536 
129,816 
115,417 
51,399 
(37,000)
14,399 

4

 
 
 
 
 
 
 
 
   
   
   
   
 
 
 
 
   
      
      
      
      
  
   
   
   
   
 
 
 
 
 
 
 
D.

Risk Factors

An investment in our capital stock involves a high degree of risk. You should carefully consider the risks described below, together with all of the
other information included in this annual report, before making an investment decision. If any of the following risks actually occurs, our business,
financial condition or results of operations could suffer. In that case, the trading price of our capital stock could decline, and you may lose all or part
of your investment.

RISKS RELATED TO OUR BUSINESS

We have incurred net losses in the past and may incur losses in the future.

In an effort to realign our business:

1. We divested most of our airport travel advertising business in 2015;

2. We terminated our advertising service at long-haul buses, gas stations completely and scaled down our on-train Wi-Fi business significantly in 2018;

3. We consolidated our efforts in providing in-flight contents of entertainment, advertising and digital multimedia in China; and,

4. We strengthened our efforts in launching and operating our in-flight connectivity business.

We have incurred net losses in recent years and in spite of our efforts to transition into our new business, we may continue to incur loss in the future. With
respect to our advertising service at gas station and our on-train Wi-Fi business, we no longer pay concession fees. With respect to providing contents on
flights,  we  have  paid,  and  expect  to  continue  to  pay  concession  fees  to  secure  time  intervals  to  play  advertising  contents.  With  respect  to  our  in-flight
connectivity business, we have incurred, and expect to continue to incur, substantial expenses in the form of acquisition of concession rights, initial system
development and installation investments and ongoing system operation and maintenance costs. In the event of any significant technology development, we
may need to incur further system development expenses. Those fees constitute a significant part of our cost of revenues and most of our concession fees are
fixed under the concession rights contracts with an escalation clause. These fees payments are usually due in advance. However, our revenues may fluctuate
significantly from period to period for various reasons. For instance, when new concession rights contracts are signed for a period, additional concession fees
are  incurred  immediately,  but  it  may  take  some  time  for  us  to  generate  revenues  from  these  concession  rights  contracts  because  it  takes  time  to  find
advertisers for the time slots and locations made available under these new contracts. Similarly, we need to purchase the bandwidth before we sell our Wi-Fi
services to users and we need to maintain our system regardless of the level of revenue. If we are not able to attract enough advertisers and customers, or at
all, our revenue will decrease and we may continue to incur losses given most of our costs and expenses are fixed.

We have a limited operating history, which may make it difficult for you to evaluate our business and prospects.

Although  we  began  our  business  operations  in  August  2005,  we  started  to  explore  our  in-flight  connectivity  business  in  2015,  and  operated  our  in-flight
content business in 2015 as well after divested our airport travel advertising business. As a result of our business realignment, our advertising service at long-
haul  buses  and  gas  stations  were  terminated  and  on-train  Wi-Fi  business  were  scaled  down  significantly  in  2018.  Our    limited  operating  history  may  not
provide a meaningful basis for you to evaluate our business, financial performance and prospects. It is also difficult to evaluate the viability of our business
model because we do not have sufficient experience to address the risks that we may encounter as we conduct our businesses. Certain members of our senior
management team, especially those who joined us only recently due to our new Wi-Fi business, have worked together for only a relatively short period of
time and it may be difficult for us to evaluate their effectiveness, on an individual or collective basis, and their ability to address future challenges to our
business. Because of our limited operating history, we may not be able to:

5

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
· manage our relationships with relevant parties to retain existing concession rights and obtain new concession rights on commercially advantageous

terms or at all;  

·

·

retain existing and acquire new advertisers and third party content providers;  

secure a sufficient number of low-cost hardware for our business from our suppliers;  

· manage our operations;  

·

·

·

successfully launch new business and operate our existing business;  

respond to competitive market conditions;  

respond to changes in the PRC regulatory regime;  

· maintain adequate control of our costs and expenses; or 

·

attract, train, motivate and retain qualified personnel.  

If advertisers or the viewing public do not accept, or lose interest in, our air travel advertising network, we may be unable to generate sufficient cash
flow from our operating activities and our business and results of operations could be materially and adversely affected.

Our success in our air travel advertising business depends on the acceptance of our advertising network by advertisers and their interest in it as a part of their
advertising strategies. In this annual report, the term “advertisers” refer to the ultimate brand-owners whose brands and products are being publicized by our
advertisements, including both advertisers that purchase advertisements directly from us and advertisers that do so through third-party advertising agencies.
Our advertisers may elect not to use our services if they believe that consumers are not receptive to our media network or that our network is not a sufficiently
effective advertising medium. If consumers find our network to be disruptive or intrusive, airplane companies may refuse to allow us to place our programs
on airplanes, and our advertisers may reduce spending on our network.

If we are not able to adequately track air traveler responses to our programs, in particular track the demographics of air travelers most receptive to air travel
advertising, we will not be able to provide sufficient feedback and data to existing and potential advertisers to help us generate demand and determine pricing.
Without improved market research, advertisers may reduce their use of air travel advertising and instead turn to more traditional forms of advertising that
have more established and proven methods of tracking the effectiveness of advertisements.

Demand  for  our  advertising  services  and  the  resulting  advertising  spending  by  our  advertisers  may  fluctuate  from  time  to  time,  and  our  advertisers  may
reduce the money they spend to advertise on our network for any number of reasons. If a substantial number of our advertisers lose interest in advertising on
our  media  network  for  these  or  other  reasons  or  become  unwilling  to  purchase  advertising  time  slots  or  locations  on  our  network,  we  will  be  unable  to
generate sufficient revenues and cash flow to operate our business, and our business and results of operations could be materially and adversely affected.

If  we  do  not  succeed  in  launching  our  in-flight  business,  our  future  results  of  operations  and  growth  prospects  may  be  materially  and  adversely
affected.

Driven by innovation, we gradually reinvented ourselves and shaped our core competence in providing in-flight solutions to connectivity, entertainment and
digital multimedia in China. We began to explore the in-flight business in 2018 and are still in the investment and development stage. We collaborated with
partners  to  deliver  in-flight  connectivity  solutions.  In  addition  to  our  active  endeavors  in  in-flight  connectivity,  we  maintain  a  wide  range  of  in-flight
entertainment and advertising contents. We may face unexpected new risks as we continue to launch this new business. As a result, we cannot assure you that
we will be able to generate enough, or any, revenue from this business. If we fail to do so, our considerable amounts of investment on system development,
will materially and adversely affect our business and financial results.

6

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In our new business, we may face new competition. If we cannot successfully address the foregoing new challenges and compete effectively, we may not be
able to develop a sufficiently large advertiser base, recover costs incurred for developing and marketing our new business, and eventually achieve profitability
from these businesses, and, consequently, our future results of operations and growth prospects may be materially and adversely affected.

We  may  be  adversely  affected  by  a  significant  or  prolonged  economic  downturn  in  the  level  of  consumer  spending  in  the  industries  and  markets
served by our customers.

Our business depends on demand for our advertising services from our customers, which is affected by the level of business activity and economic condition
of our customers and is in turn affected by the level of consumer spending in the markets our customers serve. Therefore, our businesses and earnings are
affected by general business and economic conditions in China as well as abroad.

Advertising revenues from advertisers in the automobile industry accounted for a significant portion of our revenues. Any significant or prolonged slowdown
or  decline  of  this  industry  or  the  economy  of  China,  countries  with  close  economic  ties  with  China  or  the  overall  global  economy  will  affect  consumers’
disposable income and consumer spending in these industries, and lead to a decrease in demand for our services. Furthermore, the campaign launched by the
Chinese government to curb waste by officials may also lead to decrease in demand for products of our key customers and in turn adversely affect demand for
our services.

We derive a significant portion of our revenues from the provision of air travel advertising services. A contraction in the air travel advertising
industry in China may materially and adversely affect our business and results of operations.

Approximately 89.7% of our revenues from continuing operations in 2018 was generated from the provision of air travel advertising services through the
display  of  advertisements  on  digital  TV  screens  on  airplanes.  We  expect  digital  TV  screens  on  airplanes  to  contribute  substantially  all  of  our  air  travel
network  revenue  and  a  majority  of  all  our  revenue  in  the  foreseeable  future.  If  we  cannot  successfully  generate  revenues  from  our  Wi-Fi  business,  this
situation will continue into the foreseeable future. A contraction in air travel advertising industry in China could therefore have a material adverse effect on
our business and results of operations.

If we are unable to carry out our operations as specified in existing concession rights contracts, retain or renew existing concession rights contracts
or to obtain new concession rights contracts on commercially advantageous terms, we may be unable to maintain or expand our network coverage
and our costs may increase significantly in the future.

Our ability to carry out almost all of our business depends on the availability of the necessary concession rights. However, we cannot assure you that we will
be able to carry out our operations as specified in our concession rights contracts, and any failure to perform may affect the availability of our concession
rights and materially and negatively affect our business.

We may also be unable to retain or renew concession rights contracts when they expire. Most of our concession rights contracts have no automatic renewal
provisions. We cannot assure you that we will be able to renew any or all of our concession contracts when they expire. In particular, failure to renew our Wi-
Fi concession right contracts will render it hard or impossible for us to recoup our investment in related system development and installation. We enter into
on-train  Wi-Fi  concession  rights  contracts  with  railway  administrative  bureaus,  which  are  governmental  agencies,  and  their  renewal  decisions  may  be
influenced by their supervising authorities and the changes in policies or regulations in relevant areas. We enter into in-flight Wi-Fi contracts with private
companies  operating  those  vehicles  or  the  relevant  advertising  companies  or  agencies  operated  or  hired  by  the  relevant  airline  companies,  and  those
companies are usually price sensitive and may choose not to renew our concession rights but instead enter into contracts with other players who can offer
more  competitive  pricing.  Furthermore,  even  if  we  manage  to  renew  a  concession  right  contract,  the  terms  of  the  new  contract  may  not  be  commercially
favorable to us. The concession fees that we incur under our concession rights contracts comprise a significant portion of our cost of revenues, which may
further  increase  upon  renewals.  If  we  cannot  pass  increased  concession  costs  onto  our  customers,  our  earnings  and  our  results  of  operations  could  be
materially and adversely affected. In addition, many of our concession rights contracts contain provisions granting us certain exclusive concession rights. We
cannot assure you that we will be able to retain these exclusivity provisions when we renew these contracts. If we were to lose exclusivity, our advertisers
may decide to advertise with our competitors or otherwise reduce their spending on our network and we may lose market share.

7

 
 
 
 
 
 
 
 
 
 
 
 
 
We  cannot  assure  you  that  our  concession  rights  contracts  will  not  be  unilaterally  terminated  during  their  terms,  whether  with  or  without  justification.  In
addition,  many  of  our  concession  rights  contracts  were  entered  into  with  the  advertising  companies  operated  by  or  advertising  agencies  hired  by  airline
companies, and not with the airline companies directly. Although these advertising companies and agents have generally represented to us in writing that they
have  the  rights  to  operate  advertising  media  on  airplanes  and  all  of  them  have  performed  their  contractual  obligations,  we  cannot  assure  you  that  airline
companies  will  not  challenge  or  revoke  the  contractual  concession  rights  granted  to  us  by  their  advertising  companies  or  agents;  if  such  challenges  or
revocations occur, our revenues and results of operations could be materially and adversely affected.

If we fail to properly perform our existing concession rights contracts, retain existing concession rights contracts or obtain new concession rights contracts on
commercially advantageous terms, we may be unable to maintain or expand our network coverage and our costs may increase significantly in the future.

A significant portion of our revenues has been derived from a limited number of airline companies in China. If any of these airline companies
experiences a material business or flight disruption or if there are changes in our arrangements with these airline companies, we may incur
substantial losses of revenues.

We derived a significant portion of our revenues from operations in 2018 from seven airline companies in China. As of the date of this annual report, we have
concession rights contracts to place our programs on China Southern Airline and China Eastern Airline, respectively, which in the aggregate contributed more
than a majority of our revenue from digital TV screens on airplanes in 2018. A material business or flight disruption of any of those airline companies could
negatively affect our advertising media on airplanes operated by those companies.

We  expect  our  advertising  platform  with  these  abovementioned  airline  companies  to  continue  to  contribute  a  significant  portion  of  our  revenues  in  the
foreseeable future. If any such companies experiences a material business or flight disruption, we would likely lose a substantial amount of revenues.

We depend on third-party program producers to provide the non-advertising content that we include in our programs. Failure to obtain high-quality
content  on  commercially  reasonable  terms  could  materially  reduce  the  attractiveness  of  our  network,  harm  our  reputation  and  materially  and
adversely affect our business and results of operations.

The programs on the majority of our digital TV screens include both advertising and non-advertising content. Third-party content providers and various other
television stations and television production companies have contracts with us to provide the majority of the non-advertising content played over our network,
particularly on our digital TV screens on airplanes. There is no assurance that we will be able to renew these contracts, enter into substitute contracts to obtain
similar contents or obtain non-advertising content on satisfactory terms, or at all. To make our programs more attractive, we must continue to secure contracts
with third-party content providers. If we fail to obtain a sufficient amount of high-quality content on a cost-effective basis, advertisers may find advertising on
our network unattractive and may not wish to purchase advertising time slots or locations on our network, which would materially and adversely affect our
business and results of operations.

8

 
 
 
 
 
 
 
 
 
 
 
When our current advertising network of digital TV screens and LED screens becomes saturated on the airlines where we operate, we may be unable
to offer additional time slots or locations to satisfy all of our advertisers’ needs, which could hamper our ability to generate higher levels of revenues
and profitability over time.

When our network of digital TV screens and LED screens becomes saturated in any particular airline where we operate, we may be unable to offer additional
advertising time slots or locations to satisfy all of our advertisers’ needs. We would need to increase our advertising rates for advertising in such airlines or
other locations to increase our revenues. However, advertisers may be unwilling to accept rate increases, which could hamper our ability to generate higher
levels of revenues over time. In particular, the utilization rates of our advertising time slots and locations on the three largest airlines in China are higher than
those on other airlines, and saturation or oversaturation of digital TV screens on these airlines could have a material adverse effect on our growth prospects.

Our advertising agencies could engage in activities that are harmful to our reputation in the industry and to our business.

We  engage  third-party  advertising  agencies  to  help  source  advertisers  from  time  to  time.  These  third-party  advertising  agencies  assist  us  in  identifying
advertisers and introduce advertisers to us. In return, we pay fees to these advertising agencies if they generate advertising revenues for us. Fees that we pay
to  these  third-party  agencies  are  calculated  based  on  a  pre-set  percentage  of  revenues  generated  from  the  advertisers  introduced  to  us  by  the  third-party
agencies and are paid when payments are received from the advertisers. Our contractual arrangements with these advertising agencies do not provide us with
control or oversight over their everyday business activities, and one or more of these agencies may engage in activities that violate PRC laws and regulations
governing  the  advertising  industry  and  related  non-advertising  content,  or  other  laws  and  regulations.  If  the  advertising  agencies  we  use  violate  PRC
advertising or other laws or regulations, it could harm our reputation in the industry and have detrimental effects on our business operations.

Because we rely on third-party advertising agencies to help obtain advertisers, if we fail to maintain stable business relations with key third-party
agencies or to attract additional agencies on competitive terms, our business and results of operations could be materially and adversely affected.

We  engage  third-party  advertising  agencies  to  help  obtain  advertisers  from  time  to  time.  We  do  not  have  long-term  or  exclusive  agreements  with  these
advertising agencies, including our key third-party advertising agencies, and cannot assure you that we will continue to maintain stable business relations with
them. Furthermore, the fees we pay to these third-party advertising agencies constitute a significant portion of our cost of revenues. If we fail to retain key
third-party advertising agencies or to attract additional advertising agencies, we may not be able to retain existing advertisers or attract new advertisers or
advertising agencies, or the fees we pay them may have to significantly increase. If any of the above happens, our business and results of operations could be
materially and adversely affected.

A limited number of advertisers have historically accounted for a significant portion of our revenues and this dependence may reoccur in the future,
which would make us more vulnerable to the loss of major advertisers or delays in payments from these advertisers.

A limited number of advertisers historically accounted for a significant portion of our revenues, for the years ended December 31, 2016, 2017 and 2018, nil, 1
and 2 individual customer accounted for over 10% of total revenue, respectively.

If we fail to sell our services to one or more of our major advertisers in any particular period, or if a major advertiser purchases fewer of our services, fails to
purchase  additional  advertising  time  on  our  network,  or  cancels  some  or  all  of  its  purchase  orders  with  us,  our  revenues  could  decline  and  our  operating
results  could  be  adversely  affected.  The  dependence  on  a  small  number  of  advertisers  could  leave  us  more  vulnerable  to  payment  delays  from  these
advertisers.  We  are  required  under  some  of  our  concession  rights  contracts  to  make  prepayments  and  although  we  do  receive  some  prepayments  from
advertisers, there is typically a lag between the time of our prepayment of concession fees and the time that we receive payments from our advertisers. As our
business  expands  and  revenues  grow,  we  have  experienced  and  may  continue  to  experience  an  increase  in  our  accounts  receivable.  If  any  of  our  major
advertisers are significantly delinquent with its payments, our liquidity and financial conditions may be materially and adversely affected.

9

 
 
 
 
 
 
 
 
 
 
 
 
 
We face significant competition in the advertising industry in China, and if we do not compete successfully against new and existing competitors, we
may lose our market share, and our profits may be reduced.

We face significant competition in the advertising industry in China. We compete for advertisers primarily on the basis of price, program quality, the range of
services offered and brand recognition. We primarily compete for advertising dollars spent in the air travel advertising industry. We may also face competition
from new competitors as we enter into new markets.

Significant  competition  could  reduce  our  operating  margins  and  profitability  and  lead  to  a  loss  of  market  share.  Some  of  our  existing  and  potential
competitors may have competitive advantages such as significantly greater brand recognition, a longer history in the out-of-home advertising industry and
financial, marketing or other resources, and may be able to mimic and adopt our business model. In addition, several of our competitors have significantly
larger advertising networks than we do, which gives them an ability to reach a larger number of overall potential consumers and which may make them less
susceptible than we are to downturns in particular advertising sectors, such as air travel. Moreover, significant competition will provide advertisers with a
wider  range  of  media  and  advertising  service  alternatives,  which  could  lead  to  lower  prices  and  decreased  revenues,  gross  margins  and  profits  focus.  We
cannot assure you that we will be able to successfully compete against new or existing competitors, and failure to compete may reduce for existing market
share and profits.

Our results of operations are largely subject to fluctuations in the demand for air travel. A decrease in the demand for air travel may make it difficult
for us to sell our advertising time slots and locations.

To a large extent, our results of operations are linked to the demand for air travel, which fluctuates greatly from period to period, and is subject to seasonality
due to holiday travel and weather conditions. Other factors that may affect our results include:

·

·

Downturns in the economy.  Business  travel  is  one  of  the  primary  drivers  of  the  air  travel  industry  and  it  tends  to  increase  in  times  of  economic
growth and decrease in times of economic slowdown. A decrease in air passengers in China could lead to lower advertiser spending on our air travel
advertising network.  

Plane crashes or other accidents. An aircraft crash or other accident, such as those in 2014 involving certain Asian-based airlines, could create a
public  perception  that  air  travel  is  not  safe  or  reliable,  which  could  result  in  air  travelers  being  reluctant  to  fly.  Significant  aircraft  delays  due  to
capacity constraints, weather conditions or mechanical problems could also reduce demand for air travel, especially for shorter domestic flights.  

If the demand for air travel within our network decreases for any of these or other reasons, advertisers may be reluctant to advertise on our network and we
may be unable to sell our advertising time slots or locations or charge premium prices.

Past and future acquisitions may have an adverse effect on our ability to manage our business.

We  have  acquired  and  may  continue  to  acquire  businesses,  technologies,  services  or  products  which  are  complementary  to  our  core  air  travel  advertising
network business in the future. Past and future acquisitions may expose us to potential risks, including risks associated with:

·

·

·

·

the integration of new operations, services and personnel;  

unforeseen or hidden liabilities;  

the diversion of resources from our existing business and technology; or 

failure to achieve the intended objectives of our acquisitions.  

10

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Any of these potential risks could have a material and adverse effect on our ability to manage our business, our revenues and net income.

We may need to raise additional debt or sell additional equity securities to make future acquisitions. The raising of additional debt funding by us, if required,
would  increase  debt  service  obligations  and  may  lead  to  additional  operating  and  financing  covenants,  or  liens  on  our  assets,  that  would  restrict  our
operations. The sale of additional equity securities could cause additional dilution to our shareholders.

Our acquisition strategy also depends on our ability to obtain necessary government approvals. See “– Risks Related to Doing Business in China – The M&A
Rule  sets  forth  complex  procedures  for  acquisitions  conducted  by  foreign  investors  which  could  make  it  more  difficult  to  pursue  growth  through
acquisitions.”

Our quarterly and annual operating results are difficult to predict and have fluctuated and may continue to fluctuate significantly from period to
period.

Our  quarterly  and  annual  operating  results  are  difficult  to  predict  and  have  fluctuated  and  may  continue  to  fluctuate  significantly  from  period  to
period based on the performance of our new business, the seasonality of air travel, consumer spending and corresponding advertising trends in China. Air
travel, and advertising spending in China generally tend to increase during major national holidays in October and tend to decrease during the first quarter of
each year.  Air travel and advertising spending in China is also affected by certain special events and related government measures. As a result, and also due
to the unpredictable performance of our new business, you may not be able to rely on period-to-period comparisons of our operating results as an indication
of  our  future  performance.  Other  factors  that  may  cause  our  operating  results  to  fluctuate  include  a  deterioration  of  economic  conditions  in  China  and
potential changes to the regulation of the advertising industry in China. If our revenues for a particular quarter are lower than we expect, we may be unable to
reduce our operating costs and expenses for that quarter by a corresponding amount, and it would harm our operating results for that quarter relative to our
operating results for other quarters.

Our business depends substantially on the continuing efforts of our senior executives and other key employees, and our business may be severely
disrupted if we lose their services.

Our future success heavily depends upon the continued services of our senior executives and other key employees. We rely on their industry expertise, their
experience in business operations and sales and marketing, and their working relationships with our advertisers, airlines, and relevant government authorities.

If one or more of our senior executives and other key employees were unable or unwilling to continue in their present positions, we might not be able to
replace  them  easily  or  at  all.  If  any  of  our  senior  executives  and  other  key  employees  joins  a  competitor  or  forms  a  competing  company,  we  may  lose
advertisers,  suppliers,  key  professionals  and  staff  members.  Each  of  our  executive  officers  and  other  key  employees  has  entered  into  an  employment
agreement with us which contains non-competition provisions.  However, if any dispute arises between any of our executive officers and other key employees
and us, we cannot assure you the extent to which any of these agreements could be enforced in China, where most of these executive officers and other key
employees reside, in light of the uncertainties with China’s legal system. See “—Risks Related to Doing Business in China—Uncertainties with respect to the
PRC legal system could limit the legal protections available to us or result in substantial costs and the diversion of resources and management attention.”

Failure  to  maintain  an  effective  system  of  internal  control  over  financial  reporting  and  effective  disclosure  controls  and  procedures  could  have  a
material and adverse effect on the trading price of our ADSs.

We  are  subject  to  reporting  obligations  under  the  U.S.  securities  laws.  The  SEC,  as  required  by  Section  404  of  the  Sarbanes-Oxley  Act  of  2002,  or  the
Sarbanes-Oxley  Act,  adopted  rules  requiring  every  public  company  to  include  a  management  report  on  such  company’s  internal  control  over  financial
reporting  in  its  annual  report,  which  must  also  contain  management’s  assessment  of  the  effectiveness  of  the  company’s  internal  control  over  financial
reporting. SEC rules also require every public company to include a management report containing management’s assessment of the effectiveness of such
company’s disclosure controls and procedures in its annual report.

11

 
 
 
 
 
 
 
 
 
 
 
 
 
 
We  have  identified  material  weaknesses  in  our  internal  control  over  financial  reporting,  if  we  fail  to  develop  or  maintain  an  effective  system  of  internal
controls, we may not be able to accurately report our financial results or prevent fraud. As a result, current and potential stockholders could lose confidence in
our  financial  reporting,  which  would  harm  our  business  and  the  trading  price  of  our  securities.  In  connection  with  the  audit  of  our  consolidated  financial
statements for the years ended December 31, 2018 and 2017, our management concluded that the Company had material weaknesses in its internal controls.
Our management has concluded that we had not maintained effective internal control over financial reporting and disclosure controls and procedures as of
December 31, 2018. A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a
reasonable possibility that a material misstatement of the company’s annual or interim financial statements will not be prevented or detected on a timely basis.
After identifying the material weakness regarding lack of internal controls over related party borrowings resulting in interest free loans lent to director for
personal  purpose  for  the  year  ended  December  31,  2017,  we  have  collected  all  the  borrowings  from  directors  and  have  standardized  and  improved  the
borrowing  processes  according  to  the  requirements  of  internal  control.  The  material  weaknesses  as  of  December  31,  2018  were  related  to  a)  the  weak
operating effectiveness and lack of monitoring of controls over financial reporting due to inadequate resources or resources with insufficient experience or
training  in  our  financial  reporting  team,  internal  control  team,  administration  team  and  human  resource  team,  and  b)  lack  of  internal  controls  over  risk
assessments related to third party borrowings resulting in material losses from loans to third parties.  See “Item 15. Controls and Procedures.” Any failure to
achieve  and  maintain  effective  internal  control  over  financial  reporting  could  negatively  affect  the  reliability  of  our  financial  information  and  reduce
investors’ confidence in our reported financial information, which in turn could result in lawsuits being filed against us by our shareholders, otherwise harm
our reputation or negatively impact the trading price of our ADSs. Furthermore, we have incurred and anticipate that we will continue to incur considerable
costs and use significant management time and other resources in an effort to comply with Section 404 of the Sarbanes-Oxley Act and other requirements of
the Sarbanes-Oxley Act.

We  may  need  additional  capital  which,  if  obtained,  could  result  in  dilution  or  significant  debt  service  obligations.  We  may  not  be  able  to  obtain
additional capital on commercially reasonable terms, which could adversely affect our liquidity and financial position.

We may require additional cash resources due to changed business conditions or other future developments, especially given our investment in our new Wi-Fi
business. If our current resources are insufficient to satisfy our cash requirements, we may seek to sell additional equity or debt securities or obtain a credit
facility.  The  sale  of  convertible  debt  securities  or  additional  equity  securities  could  result  in  additional  dilution  to  our  shareholders.  The  incurrence  of
indebtedness would result in increased debt service obligations and could result in operating and financing covenants that would restrict our operations and
liquidity.

In addition, our ability to obtain additional capital on acceptable terms is subject to a variety of uncertainties, including:

·

·

·

·

investors’ perception of, and demand for, securities of alternative advertising media companies;  

conditions of the market;  

our future results of operations, financial condition and cash flows; and 

PRC governmental regulation of foreign investment in advertising services companies in China.  

We cannot assure you that financing will be available in amounts or on terms acceptable to us, if at all. Any failure to raise additional funds on favorable
terms could have a material adverse effect on our liquidity and financial condition.

Compliance with PRC laws and regulations may be difficult and could be costly, and failure to comply could subject us to government sanctions.

As an advertising service provider, we are obligated under PRC laws and regulations to monitor the advertising content shown on our network for compliance
with  applicable  law.  Violation  of  these  laws  or  regulations  may  result  in  penalties,  including  fines,  confiscation  of  advertising  fees,  orders  to  cease
dissemination of the offending advertisements and orders to publish advertisements correcting the misleading information. In case of serious violations, the
PRC  authorities  may  revoke  our  license  for  advertising  business  operations.  In  general,  the  advertisements  shown  on  our  network  have  previously  been
broadcast  over  public  television  networks  and  have  been  subjected  to  internal  review  and  verification  by  such  networks,  but  we  are  still  required  to
independently review and verify these advertisements for content compliance before displaying them. In addition, if a special government review is required
for  certain  product  advertisements  before  they  are  shown  to  the  public,  we  are  required  to  confirm  that  such  review  has  been  performed  and  approval
obtained. For advertising content related to certain types of products and services, such as food products, alcohol, cosmetics, pharmaceuticals and medical
procedures, we are required to confirm that the advertisers have obtained requisite government approvals, including review of operating qualifications, proof
of quality inspection of the advertised products, government pre-approval of the contents of the advertisement and filing with local authorities.

12

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
We endeavor to comply with such requirements through means such as requesting relevant documents from the advertisers. However, we cannot assure you
that  each  advertisement  that  an  advertiser  provides  to  us  and  which  we  include  in  our  network  programs  is  in  full  compliance  with  all  relevant  PRC
advertising  laws  and  regulations  or  that  such  supporting  documentation  and  government  approvals  provided  to  us  are  complete.  Although  we  employ
qualified advertising inspectors who are trained to review advertising content for compliance with relevant PRC laws and regulations, the content standards in
the PRC are less certain and less clear than those in more developed countries such as the United States and we cannot assure you that we will always be able
to properly review all advertising content to comply with the PRC standards imposed on us with certainty.

In  addition,  although  we  use  our  best  efforts  to  comply  with  all  relevant  laws  and  regulations  and  to  obtain  all  necessary  certificates,  registrations  and
approvals for our business, due to the complexity of local laws and regulations across China governing outdoor media advertising platforms, there can be no
assurance  that  we  will  be  able  to  obtain  or  maintain  all  necessary  approvals.  For  example,  our  Wi-Fi  business  might  be  regarded  as  value-added
telecommunication  service.  To  provide  this  type  of  services,  we  are  required  to  obtain  the  relevant  telecommunication  license  from  the  communication
authorities. As a result, we cannot assure you that we will be able to obtain the necessary license soon, if at all, to provide Wi-Fi service. Any delay or failure
in obtaining such approvals or licenses could materially and adversely affect our results of operations.

We may be subject to, and may expend significant resources in defending against government actions and civil suits based on the content we provide through
our advertising network.

Because  of  the  nature  and  content  of  the  information  displayed  on  our  network,  civil  claims  may  be  filed  against  us  for  fraud,  defamation,  subversion,
negligence,  copyright  or  trademark  infringement  or  other  violations.  Offensive  and  objectionable  content  and  legal  standards  for  defamation  and  fraud  in
China are less defined than in other more developed countries and we may not be able to properly screen out unlawful content. If consumers find the content
displayed on our network to be offensive, the relevant airlines, gas stations, railway bureaus and long-haul bus companies may seek to hold us responsible for
any consumer claims or may terminate their relationships with us.

In  addition,  if  the  security  of  our  content  management  system  is  breached  and  unauthorized  images,  text  or  audio  sounds  are  displayed  on  our  network,
viewers or the PRC government may find these images, text or audio sounds to be offensive, which may subject us to civil liability or government censure
despite our efforts to ensure the security of our content management system. Any such event may also damage our reputation. If our advertising viewers do
not believe our content is reliable or accurate, our business model may become less appealing to viewers in China and our advertisers may be less willing to
place advertisements on our network.

We may be subject to intellectual property infringement claims, which may force us to incur substantial legal expenses and, if determined adversely
against us, may materially and adversely affect our business.

Our commercial success depends to a large extent on our ability to operate without infringing the intellectual property rights of third parties. We cannot assure
you that our displays or other aspects of our business do not or will not infringe patents, copyrights or other intellectual property rights held by third parties.
We may become subject to legal proceedings and claims from time to time relating to the intellectual property of others in the ordinary course of our business.
If we are found to have violated the intellectual property rights of others, we may be enjoined from using such intellectual property, incur licensing fees or be
forced  to  develop  alternatives.  In  addition,  we  may  incur  substantial  expenses  and  diversion  of  management  time  in  defending  against  these  third-party
infringement claims, regardless of their merit. Successful infringement or licensing claims against us may result in substantial monetary liabilities, which may
materially and adversely affect our business.

13

 
 
 
 
 
 
 
 
 
 
 
We face risks related to natural disasters, health epidemics and other outbreaks, which could significantly disrupt our operations.

Our business could be materially and adversely affected by natural disasters or the outbreak of health epidemic. Any such occurrences could cause severe
disruption to our daily operations, and may even require a temporary closure of our facilities. In August 2014, a strong earthquake hit part of Yunnan province
in south, and resulted in significant casualties and property damage. While we did not suffer any loss or experience any significant increase in cost resulting
from  these  earthquakes,  if  a  similar  disaster  were  to  occur  in  the  future  affecting  Beijing  or  another  city  where  we  have  major  operations  in  China,  our
operations could be materially and adversely affected due to loss of personnel and damages to property. In addition, any outbreak of avian flu, severe acute
respiratory syndrome (SARS), influenza A (H1N1), H7N9, Ebola, or other adverse public health epidemic in China may have a material and adverse effect on
our business operations. These occurrences could require the temporary closure of our offices or prevent our staff from traveling to our customers’ offices to
provide services. Such closures could severely disrupt our business operations and adversely affect our results of operations. These occurrences could reduce
air and train traveling in China and adversely affect the results of operations of our related business.

RISKS RELATED TO OUR CORPORATE STRUCTURE

If the PRC government finds that the agreements that establish the structure for operating our China business do not comply with PRC governmental
restrictions on foreign investment in the advertising industry and in the operating of non-advertising content, our business could be materially and
adversely affected.

Substantially  all  of  our  operations  are  conducted  through  contractual  arrangements  with  our  consolidated  VIEs  in  China:  AirMedia  Online  Network
Technology Group Co., Ltd. (previously known as AirMedia Online Network Technology Co., Ltd.) or AM Online, Beijing Linghang Shengshi Advertising
Co., Ltd. (Formerly Beijing AirMedia Shengshi Advertising Co., Ltd.), or Linghang Shengshi (Formerly “AirMedia Shengshi”), Beijing Wangfan Jiaming
Advertising Co.,Ltd. (Formerly Beijing AirMedia Jiaming Advertising Co., Ltd.), or Jiaming Advertising, Beijing Yuehang Digital Media Advertising Co.,
Ltd.,  or  Beijing  Yuehang  (Formerly  “AM  Yuehang”)  and  Guangzhou  Meizheng  Online  Network  Technology  Co.,  Ltd.  (formerly  known  as  Guangzhou
Meizheng Advertising Co., Ltd.), or Guangzhou Meizheng. As the Foreign-invested Advertising Enterprise Management Regulations, or the Foreign-invested
Advertising Regulations, which became effective on October 1, 2008 and has been abolished on June 29, 2015, it currently permit 100% foreign ownership of
companies that provide advertising services, subject to approval by relevant PRC government authorities. In addition, the Special Administrative Measures
for Access of Foreign Investment (Negative List) (2018 Edition), which became effective on July 28, 2018, stated that television program production and
operation  companies  fall  into  the  category  of  a  prohibited  foreign  investment  industry.  We  believe  that  these  regulations  apply  to  our  business  and  are
therefore carrying out the portions of our business that involve the production of non-advertising content through our VIEs. Our wholly owned Hong Kong
subsidiary Air Net (China) Limited (Formerly AirMedia (China) Limited) , or AN China (Formerly “AM China”), the 100% shareholder of our three wholly
foreign  owned  subsidiaries  in  China,  has  been  operating  an  advertising  business  in  Hong  Kong  since  2008,  and  thus  it  is  allowed  to  directly  invest  in
advertising business in China. In December 2014, we transferred 100% equity interest in Shenzhen Yuehang Information Technology Co., Ltd. (Formerly
Shenzhen AirMedia Information Technology Co., Ltd.), or Shenzhen Yuehang (Formerly “Shenzhen AM”), to AN China to provide advertising services in
China directly. In July 2015, Shenzhen Yuehang obtained the approval to include advertising in its scope of business. We therefore intent to gradually shift
our  advertising  business  to  Shenzhen  Yuehang  to  gradually  reduce  our  reliance  on  the  current  VIE  structure  in  terms  of  our  advertising  business.  Our
advertising  business  is  currently  primarily  provided  through  our  contractual  arrangements  with  certain  of  our  consolidated  VIEs  in  China.  These  entities
directly operate our air advertising network, enter into concession rights contracts related to our air advertising network and sell advertising time slots and
locations to our advertisers. In addition, under current PRC regulations, a foreign entity is prohibited from owning more than 50% of any PRC entity that
provides value-added telecommunication services, and Wi-Fi services might be regarded as value-added telecommunication business. As a result, we enter
into  concession  rights  contracts  related  to  our  Wi-Fi  business  via  AM  Online,  which  is  expected  to  directly  operate  this  business.  We  have  contractual
arrangements with these VIEs pursuant to which we, through Yuehang Chuangyi Technology (Beijing) Co., Ltd. (Formerly AirMedia Technology (Beijing)
Co., Ltd.), or Chuangyi Technology (“Formerly “AM Technology”), provide technical support and consulting services and other services to these entities. We
also have agreements with our VIEs and each of their individual shareholders (except Yi Zhang) that provide us with the substantial ability to control these
entities. For a description of these contractual arrangements, see “Item 4. Information on the Company—C. Organizational Structure” and “Item 7. Major
Shareholders and Related Party Transactions—B. Related Party Transactions—Contractual Arrangements.”

14

 
 
 
 
 
 
 
 
 
In January 2016, we, through the nominee shareholders of the respective VIEs, transferred 3.5% equity interest in each of AM Online, Linghang Shengshi
and  Jiaming  Advertising  to  Yi  Zhang.  Yi  Zhang  is  an  unrelated  third  party  minority  shareholder  of  those  VIEs  and  did  not  enter  into  the  same  VIE
arrangements with us as did the other nominee shareholders. In December 31, 2018, Yi Zhang has withdrawn all the 3.5% equity interest, we therefore can
exert the same level of control over the 3.5% interests of the VIEs owned by Yi Zhang.

Some  of  our  VIE  arrangements  with  Linghang  Shengshi  and  Jiaming  Advertising  may  expire  on  June  13,  2027  if  any  party  thereto  sends  a  no-extension
notice to the other at least twenty (20) days in advance. Although we believe we can renew those agreements with the VIEs and their shareholders at that
time, if we fail to do so, our control over such VIEs might be adversely affected.

In the opinion of Commerce & Finance Law Offices, our PRC counsel, except as described in this annual report, the VIE arrangements between Chuangyi
Technology and our consolidated VIEs, as described in this annual report, do not violate PRC law and are valid, binding and legally enforceable.  However,
uncertainties in the PRC legal system could limit our ability to enforce these contractual arrangements and if the shareholders of the VIEs were to reduce their
interest in us, their interests may diverge from ours and that may potentially increase the risk that they would seek to act contrary to the contractual terms, for
example by influencing the VIEs not to pay the service fees when required to do so.

Our ability to control the VIEs also depends on the power of attorney Chuangyi Technology has to vote on all matters requiring shareholder approval in the
VIEs. As noted above, we believe this power of attorney is legally enforceable but may not be as effective as direct equity ownership.

In addition, if the PRC government were to find that the VIE arrangements do not comply with PRC governmental restrictions on foreign investment in the
advertising industry and in the operating of non-advertising content, or if the legal structure and contractual arrangements were found to be in violation of any
other existing PRC laws and regulations, the PRC government could:

·

·

·

·

revoke the business and operating licenses of the our PRC subsidiaries and affiliates;  

discontinue or restrict the our PRC subsidiaries’ and affiliates’ operations;  

impose conditions or requirements with which we or our PRC subsidiaries and affiliates may not be able to comply; or 

require us or our PRC subsidiaries and affiliates to restructure the relevant ownership structure or operations.  

While we do not believe that any penalties imposed or actions taken by the PRC government would result in the liquidation of us, Chuangyi Technology, or
the VIEs, the imposition of any of these penalties may result in a material and adverse effect on our ability to conduct the our business. In addition, if the
imposition of any of these penalties causes us to lose the power to direct the activities of the VIEs (and VIEs’ subsidiaries) that most significantly impact the
VIEs (and VIEs’ subsidiaries) economic performance or the right to receive substantially all of the benefits from the VIEs (and VIEs’ subsidiaries), we would
no longer be able to consolidate the VIEs (and VIEs’ subsidiaries).

In December 2018, the National People’s Congress of the PRC, or the NPC, released another draft of foreign investment law, or the Foreign Investment Law,
for soliciting public comments. On March 15, 2019, the Foreign Investment Law was enacted by the NPC and will become effective on January 1, 2020.
Although  the  Foreign  Investment  Law  does  not  explicitly  define  the  contractual  arrangements  with  VIEs  as  a  form  of  foreign  investment,  it  contains  an
ambiguous clause that covers other form stipulated in laws, administrative regulations or other methods prescribed by the State Council within its definition
of foreign investment. Therefore, uncertainties still exist about whether our contractual arrangements with VIEs will be deemed to violate the market access
requirements  for  foreign  investment  under  the  PRC  laws.  Additionally,  if  the  State  Council  or  laws,  administrative  regulations  require  further  actions
regarding  the  existing  contractual  arrangements  with  VIEs,  we  may  not  complete  such  actions  in  a  timely  manner,  or  at  all,  which  may  materially  and
adversely affect our business operation and financial condition.

15

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Because some of the shareholders of our VIEs in China are our directors and officers, their fiduciary duties to us may conflict with their respective
roles in the VIEs, and their interest may not be aligned with the interests of our unaffiliated public security holders. If any of the shareholders of our
VIEs fails to act in the best interests of our company or our shareholders, our business and results of operations may be materially and adversely
affected.

Certain of our directors and officers are shareholders in the VIEs, AM Online, Linghang Shengshi, Jiaming Advertising, and Beijing Yuehang. Mr. Herman
Man Guo, our chairman and chief executive officer, in addition to holding 15.3% in our company, also directly and indirectly holds approximately 77.2% of
AM Online, 83.6% of Linghang Shengshi and 1.00% of Jiaming Advertising. Mr. Qing Xu, our director and executive president, in addition to holding 1.3%
of our company, also directly and indirectly holds approximately 14.5% of AM Online, 12.50% of Linghang Shengshi and 0.21% of Jiaming Advertising. In
addition, Mr. Guo and Mr. Xu are each a director of Jiaming Advertising, Linghang Shengshi and AirMedia Group Co., Ltd. (“AM Advertising”), Mr. Guo is
the legal representative of each of Linghang Shengshi and Jiaming Advertising. For these directors and officers, their fiduciary duties toward our company
under Cayman Islands law—to act honestly, in good faith and with a view to our best interests—may conflict with their roles in the VIEs, as what is in the
best interest of the VIEs may not be in the best interests of our company or the unaffiliated public shareholders of our company.

Currently,  we  do  not  have  agreements  in  place  that  solely  target  to  resolve  conflicts  of  interest  arising  between  our  company  and  the  VIEs  and  their
operations.  In  addition,  we  have  not  appointed  a  separate  fiduciary—one  without  potential  conflicts  of  interest—to  serve  as  the  fiduciary  of  the  public
unaffiliated security holders of our company. Although our independent directors or disinterested officers may take measures to prevent the parties with dual
roles  from  making  decisions  that  may  favor  themselves  as  shareholders  of  the  VIEs,  we  cannot  assure  you  that  these  measures  would  be  effective  in  all
instances. If the parties with dual roles do find ways to make and carry out decisions on our behalf that are detrimental to our interest, our business and results
of operations may be materially and adversely affected.

Certain provisions in the contractual agreements between Chuangyi Technology and our VIEs do impose limits on the rights of the shareholders of the VIEs.
For example, each of the individual shareholders of the VIEs (except Yi Zhang) has signed an irrevocable power of attorney authorizing the person designated
by Chuangyi Technology to exercise its rights as shareholder, including the voting rights, the right to enter into legal documents and the right to transfer its
equity interest in the VIEs. However, we cannot assure you that when conflicts of interest arise that each of our VIEs and its respective shareholders will act
completely in our interests or that conflicts of interests will be resolved in our favor, or that the above contractual provisions would be sufficient protection for
us in the event that shareholders of the VIEs fail to perform under their contracts with Chuangyi Technology. In any such event, we would have to rely on
legal remedies under PRC law, which may not be effective. See “—We rely on contractual arrangements with our consolidated variable interest entities and
their shareholders for a substantial portion of our China operations, which may not be as effective as direct ownership in providing operational control” and
“Item 7. Major Shareholders and Related Party Transactions—B. Related Party Transactions—Contractual Arrangements.”

We rely on contractual arrangements with our consolidated variable interest entities and their shareholders for a substantial portion of our China
operations, which may not be as effective as direct ownership in providing operational control.

We rely on contractual arrangements with AM Online, Linghang Shengshi, Jiaming Advertising and Beijing Yuehang to operate our Wi-Fi and air advertising
business. For a description of these arrangements, see “Item 4. Information on the Company—C. Organizational Structure” and “Item 7. Major Shareholders
and  Related  Party  Transactions—B.  Related  Party  Transactions—Contractual  Arrangements.”  These  contractual  arrangements  may  not  be  as  effective  as
direct ownership in providing control over our VIEs. Under these contractual arrangements, if our VIEs or their shareholders fail to perform their respective
obligations, we may have to incur substantial costs and resources to enforce such arrangements and rely on legal remedies under PRC law, including seeking
specific performance or injunctive relief and claiming damages, and we may not be successful.

16

 
 
 
 
 
 
 
 
 
 
Many of these contractual arrangements are governed by PRC law and provide for disputes to be resolved through arbitration or litigation in the PRC. The
legal environment in the PRC is not as developed as in other jurisdictions such as the United States. As a result, uncertainties in the PRC legal system could
limit our ability to enforce these contractual arrangements, which may make it difficult to exert effective control over our VIEs, and our ability to conduct our
business may be negatively affected.

We have not registered the pledge of equity interest by certain shareholder of our consolidated affiliated entities with the relevant authority, and we
may  not  be  able  to  enforce  the  equity  pledge  against  any  third  parties  who  acquire  the  equity  interests  in  good  faith  in  the  relevant  consolidated
affiliated entities before the pledge is registered.

Except for Yi Zhang, who acquired 3.5% minority equity interest in each of AM Online, Linghang Shengshi and Jiaming Advertising in January 2016, the
individual  shareholders  of  our  VIEs,  each  a  consolidated  affiliated  entity  of  ours,  have  pledged  all  of  their  equity  interests,  including  the  right  to  receive
declared dividends, in the relevant VIEs to Chuangyi Technology, our wholly-owned subsidiary. An equity pledge agreement becomes effective among the
parties upon execution, but according to the PRC Property Rights Law, an equity pledge is not perfected as a security property right unless it is registered with
the relevant local administration for industry and commerce. We have not yet registered the share pledges by shareholders of AM Online, Linghang Shengshi
and Jiaming Advertising. As the registration of these pledges has not yet been completed so far, the pledges, as property rights, have not yet become effective
under the PRC Property Rights Law. Before the registration procedures are completed, we cannot assure you that the effectiveness of these pledges will be
recognized by PRC courts if disputes arise with respect to certain pledged equity interests or that Chuangyi Technology’s interests as pledgee will prevail over
those of third parties. Chuangyi Technology may not be able to successfully enforce these pledges against any third parties who have acquired property right
interests in good faith in the equity interests in AM Online, Linghang Shengshi and Jiaming Advertising. As a result, if AM Online, Linghang Shengshi or
Jiaming Advertising breaches their respective obligations under the various agreements described above, and there are third parties who have acquired equity
interests in good faith, Chuangyi Technology would need to resort to legal proceedings to enforce its contractual rights under the equity pledge agreements, or
the underlying agreements secured by the pledges. We do not have agreements that pledge the assets of the VIEs and their respective subsidiaries for the
benefit of us or our wholly owned subsidiaries.

Contractual  arrangements  we  have  entered  into  among  our  subsidiaries  and  variable  interest  entities  may  be  subject  to  scrutiny  by  the  PRC  tax
authorities and a finding that we owe additional taxes could substantially increase our taxes owed and reduce our net income and the value of your
investment.

Under PRC law, arrangements and transactions among related parties may be audited or challenged by the PRC tax authorities. If any transactions we have
entered into among Chuangyi Technology and our VIEs are found not to be on an arm’s length basis, or to result in an unreasonable reduction in tax under
PRC law, the PRC tax authorities have the authority to disallow our tax savings, adjust the profits and losses of our respective PRC entities and assess late
payment interest and penalties. A finding by the PRC tax authorities that we are ineligible for the tax savings we achieved would substantially increase our
taxes owed and reduce our net income and the value of your investment.

We  may  rely  principally  on  dividends  and  other  distributions  on  equity  paid  by  our  wholly-owned  operating  subsidiaries  to  fund  any  cash  and
financing requirements we may have, and any limitation on the ability of our operating subsidiaries to pay dividends to us could have a material
adverse effect on our ability to conduct our business.

We are a holding company, and we may rely principally on dividends and other distributions on equity paid by Chuangyi Technology, Shenzhen Yuehang and
Xi’an  Shengshi  Dinghong  Information  Technology  Co.,  Ltd.  (Formerly  Xi’an  AirMedia  Chuangyi  Technology  Co.,  Ltd.),  or  Xi’an  Shengshi  for  our  cash
requirements, including the funds necessary to service any debt we may incur. If Chuangyi Technology, Shenzhen Yuehang or Xi’an Shengshi incurs debt on
its own behalf in the future, the instruments governing the debt may restrict the ability of these entities to pay dividends or make other distributions to us. In
addition, the PRC tax authorities may require us to adjust our taxable income under the contractual arrangements Chuangyi Technology currently has in place
with our VIEs in a manner that would materially and adversely affect Chuangyi Technology’s ability to pay dividends and other distributions to us.

17

 
 
 
 
 
 
 
 
 
 
 
Furthermore, relevant PRC laws and regulations permit payments of dividends by Chuangyi Technology, Shenzhen Yuehang and Xi’an Shengshi only out of
their accumulated profits, if any, as determined in accordance with PRC accounting standards and regulations. Under PRC laws and regulations, Chuangyi
Technology, Shenzhen Yuehang and Xi’an Shengshi are also required to set aside at least 10% of after-tax income based on PRC accounting standards each
year to their general reserves until the accumulative amount of such reserves reaches 50% of their respective registered capital.

The registered capital of Chuangyi Technology, Shenzhen Yuehang and Xi’an Shengshi is $45.0 million, $96.4 million (approximately RMB700 million) and
$50.0  million,  respectively.  Xi’an  Shengshi  has  made  the  applicable  annual  appropriations  required  under  PRC  law.  Chuangyi  Technology  and  Shenzhen
Yuehang are not currently required to fund any statutory surplus reserve because Chuangyi Technology incurred loss this year and Shenzhen Yuehang still has
accumulated  losses.  Any  direct  or  indirect  limitation  on  the  ability  of  our  PRC  subsidiaries  to  distribute  dividends  and  other  distributions  to  us  could
materially and adversely limit our ability to make investments or acquisitions at the holding company level, pay dividends or otherwise fund and conduct our
business.

Although none of Chuangyi Technology, Shenzhen Yuehang or Xi’an Shengshi has any present plan to pay any cash dividends to us in the foreseeable future,
any  limitation  on  the  ability  of  Chuangyi  Technology,  Shenzhen  Yuehang  or  Xi’an  Shengshi  to  pay  dividends  or  make  other  distributions  to  us  could
materially and adversely limit our ability to grow, make investments or acquisitions that could be beneficial to our business, or otherwise fund and conduct
our business.

RISKS RELATED TO DOING BUSINESS IN CHINA

Adverse changes in the political and economic policies of the PRC government could have a material adverse effect on the overall economic growth
of China, which could reduce the demand for our services and have a material adverse effect on our competitive position.

Substantially all of our assets are located in China and substantially all of our revenues are derived from our operations in China. Accordingly, our business,
financial  condition,  results  of  operations  and  prospects  are  affected  significantly  by  China’s  economic,  political  and  legal  developments.  The  Chinese
economy differs from the economies of most developed countries in many respects, including the level of government involvement and the level and growth
rate of economic development.

While the Chinese economy has experienced significant growth in the past decades, growth has been uneven both geographically and among various sectors
of the economy, and the rate of growth has been slowing. The PRC government has implemented various measures to encourage economic growth and guide
the allocation of resources. Some of these measures may benefit the overall Chinese economy, but may also have a negative effect on us. We cannot predict
the future direction of political or economic reforms or the effects such measures may have on our business, financial position or results of operations. Any
adverse change in the political or economic conditions in China, including changes in the policies of the PRC government or in laws and regulations in China,
could  have  a  material  adverse  effect  on  the  overall  economic  growth  of  China  and  the  industries  in  which  we  operate.  Such  developments  could  have  a
material adverse effect on our business, lead to a reduction in demand for our services and materially and adversely affect our competitive position.

Uncertainties with respect to the PRC legal system could limit the legal protections available to us or result in substantial costs and the diversion of
resources and management attention.

We conduct our business primarily through Beijing Yuehang Digital and AM Online, which are subject to PRC laws and regulations applicable to foreign
investment in China and, in particular, laws applicable to wholly-foreign owned companies. The PRC legal system is based on written statutes. Prior court
decisions may be cited for reference but have limited precedential value. PRC legislation and regulations afford significant protections to various forms of
foreign investments in China, but since these laws and regulations are relatively new and the PRC legal system continues to rapidly evolve, the interpretations
of many laws, regulations and rules are not always uniform and the enforcement of these laws, regulations and rules involve uncertainties, which may limit
the legal protections available to us. In addition, any litigation in China may be protracted and result in substantial costs and the diversion of resources and
management attention.

18

 
 
 
 
 
 
 
 
 
 
 
 
 
Fluctuations in the value of the Renminbi may have a material adverse effect on your investment.

The value of the RMB against the U.S. dollar and other currencies is affected by changes in China’s political and economic conditions and by China’s foreign
exchange policies, among other things. In July 2005, the PRC government changed its decades-old policy of pegging the value of the RMB to the U.S. dollar,
and the RMB appreciated more than 20% against the U.S. dollar over the following three years. Between July 2008 and June 2010, this appreciation halted
and the exchange rate between the RMB and the U.S. dollar remained within a narrow band. Since June 2010, the RMB has fluctuated against the U.S. dollar,
at times significantly and unpredictably. Since October 1, 2016, Renminbi has joined the International Monetary Fund (IMF)’s basket of currencies that make
up the Special Drawing Right (SDR), along with the U.S. dollar, the Euro, the Japanese yen and the British pound. In the fourth quarter of 2016, Renminbi
has depreciated significantly in the backdrop of a surging U.S. dollar and persistent capital outflows of China. With the development of the foreign exchange
market and progress towards interest rate liberalization and Renminbi internationalization, the PRC government may in the future announce further changes
to  the  exchange  rate  system  and  there  is  no  guarantee  that  Renminbi  will  not  appreciate  or  depreciate  significantly  in  value  against  the  U.S.  dollar  in  the
future. It is difficult to predict how market forces or PRC or U.S. government policy may impact the exchange rate between the RMB and the U.S. dollar in
the future.

The reporting and functional currency of our Cayman Islands parent company is the U.S. dollar. However, substantially all of the revenues and expenses of
our  consolidated  operating  subsidiaries  and  affiliate  entities  are  denominated  in  Renminbi.  Substantially  all  of  our  sales  contracts  are  denominated  in
Renminbi  and  substantially  all  of  our  costs  and  expenses  are  denominated  in  Renminbi.  Any  significant  appreciation  or  depreciation  of  the  RMB  may
materially and adversely affect our revenues, earnings and financial position, and the value of, and any dividends payable on, our ADSs in U.S. dollars. To the
extent that we need to convert U.S. dollars into Renminbi for our operations, depreciation of the Renminbi against the U.S. dollar would have an adverse
effect  on  the  Renminbi  amount  we  receive  from  the  conversion.  Conversely,  if  we  decide  to  convert  our  Renminbi  into  U.S.  dollars  for  the  purpose  of
dividend  distribution  or  for  other  business  purposes,  depreciation  of  the  U.S.  dollar  against  the  Renminbi  would  have  a  negative  effect  on  the  U.S.  dollar
amount available to us. Fluctuations in the exchange rate will also affect the relative value of any dividend we issue which will be exchanged into U.S. dollars
and earnings from and the value of any U.S. dollar-denominated investments we make in the future.

Very limited hedging transactions are available in China to reduce our exposure to exchange rate fluctuations. To date, we have not entered into any hedging
transactions in an effort to reduce our exposure to foreign currency exchange risk. While we may decide to enter into hedging transactions in the future, the
availability and effectiveness of these hedges may be limited so that we may not be able to successfully hedge our exposure at all. In addition, our currency
exchange  losses  may  be  magnified  by  PRC  exchange  control  regulations  that  restrict  our  ability  to  convert  Renminbi  into  foreign  currency.  As  a  result,
fluctuations in exchange rates may have a material adverse effect on your investment.

Restrictions on currency exchange may limit our ability to receive and use our revenues or financing effectively.

Substantially all of our revenues and expenses are denominated in Renminbi. We may need to convert a portion of our revenues into other currencies to meet
our foreign currency obligations, including, among others, payments of dividends declared, if any, in respect of our ordinary shares or ADSs. Under China’s
existing foreign exchange regulations, Chuangyi Technology, Shenzhen Yuehang and Xi’an Shengshi are able to pay dividends in foreign currencies, without
prior approval from the State Administration of Foreign Exchange, or the SAFE, by complying with certain procedural requirements. However, we cannot
assure you that the PRC government will not take measures in the future to restrict access to foreign currencies for current account transactions.

19

 
 
 
 
 
 
 
 
 
 
Foreign exchange transactions by our subsidiaries and VIEs in China under capital accounts continue to be subject to significant foreign exchange controls
and require the approval of, or registration with, PRC governmental authorities. In particular, if we or other foreign lenders make foreign currency loans to
our subsidiaries or VIEs in China, these loans must be registered with the SAFE, and if we finance them by means of additional capital contributions, these
capital contributions must be approved by or registered with certain government authorities including the SAFE, the Ministry of Commerce or their local
counterparts.  These  limitations  could  affect  the  ability  of  our  subsidiaries  in  China  to  exchange  the  foreign  currencies  obtained  through  debt  or  equity
financing, and could affect our business and financial condition.

On August 29, 2008, SAFE promulgated the Circular on the Relevant Operating Issues Concerning the Improvement of the Administration of the Payment
and Settlement of Foreign Currency Capital of Foreign Invested Enterprises, or SAFE Circular 142, regulating the conversion by a foreign-invested enterprise
of  foreign  currency  registered  capital  into  RMB  by  restricting  how  the  converted  RMB  may  be  used.  SAFE  Circular  142  provides  that  the  RMB  capital
converted from foreign currency registered capital of a foreign-invested enterprise may only be used within the purpose within the business scope approved
by the applicable government authority and unless otherwise provided by law, such RMB capital may not be used for equity investments within the PRC. In
addition, SAFE strengthened its oversight of the flow and use of the RMB capital converted from foreign currency registered capital of a foreign-invested
company. The use of such RMB capital may not be altered without SAFE approval, and such RMB capital may not in any case be used to repay RMB loans if
the proceeds of such loans have not been used. Violations of SAFE Circular 142 could result in severe monetary or other penalties. On November 9, 2011,
SAFE promulgated the Circular of the State Administration of Foreign Exchange on Issues Relating to Further Clarification and Regulation of Certain Capital
Account Items under Foreign Exchange Control (“Circular 45”) to further strengthen and clarify its existing regulations on foreign exchange control under
SAFE Circular 142. Circular 45 expressly prohibits foreign invested entities, including wholly foreign owned enterprises such as Chuangyi Technology, from
converting registered capital in foreign exchange into RMB for the purpose of equity investment, granting certain loans, repayment of inter-company loans,
and repayment of bank loans which have been transferred to a third party. Further, Circular 45 generally prohibits a foreign invested entity from converting
registered capital in foreign exchange into RMB for the payment of various types of cash deposits. If our VIEs require financial support from us or our wholly
foreign-owned enterprises in the future and we find it necessary to use foreign currency-denominated capital to provide such financial support, our ability to
fund the VIEs’ operations will be subject to statutory limits and restrictions, including those described above.

Circular 45 was abolished by SAFE on March 19, 2015 according to a Circular on Promulgating the Abolishment and Invalidation of 50 Foreign Exchange-
related  Regulatory  Documents.  On  March  30,  2015,  SAFE  promulgated  the  Circular  on  Reforming  the  Management  Approach  Regarding  the  Foreign
Exchange Capital Settlement of Foreign-invested Enterprises, or SAFE Circular 19, which took effect on June 1, 2015 and replaced SAFE Circular 142. On
June 9, 2016, the SAFE promulgated the Circular of the State Administration of Foreign Exchange on Reforming and Regulating Policies on the Control over
Foreign Exchange Settlement of Capital Accounts, or SAFE Circular 16, which revised some provisions of SAFE Circular 19. SAFE Circular 19 and SAFE
Circular 16 allow foreign-invested enterprises to settle 100% of their foreign exchange capitals on a discretionary basis and allows ordinary foreign-invested
enterprises to make domestic equity investments by capital transfer in the original currencies, or with the amount obtained from foreign exchange settlement,
subject  to  complying  with  certain  requirements.  According  to  SAFE  Circular  19  and  SAFE  Circular  16,  the  RMB  funds  obtained  by  foreign-invested
enterprises  from  the  discretionary  settlement  of  foreign  exchange  capitals  shall  be  managed  under  the  accounts  pending  for  foreign  exchange  settlement
payment, and foreign-invested enterprise shall not use its capital and the RMB funds obtained from foreign exchange settlement for the purposes within the
following negative list: for expenditure beyond its business scope or expenditure prohibited by laws and regulations, for investments in securities or other
investments  than  banks’  principal-secured  products,  for  the  granting  of  loans  to  non-affiliated  enterprises,  except  where  it  is  expressly  permitted  in  the
business license, or for construction or expenses related to the purchase of real estate not for self-use, unless it is a foreign-invested real estate enterprise.
Nevertheless, it is still not clear whether foreign-invested enterprises like our PRC subsidiaries are allowed to extend intercompany loans to our VIEs.

20

 
 
 
 
 
 
 
PRC regulations relating to the establishment of offshore special purpose companies by PRC residents and registration requirements for employee
stock ownership plans or share option plans may subject our PRC resident beneficial owners or the plan participants to personal liability, limit our
ability to inject capital into our PRC subsidiaries, limit our subsidiaries’ ability to increase their registered capital or distribute profits to us, or may
otherwise adversely affect us.

Regulations promulgated by the SAFE require PRC residents and PRC corporate entities to register with local branches of the SAFE in connection with their
direct  or  indirect  offshore  investment  activities.  These  regulations  apply  to  our  shareholders  who  are  PRC  residents  and  may  apply  to  any  offshore
acquisitions that we make in the future.

On  February  15,  2012,  the  SAFE  promulgated  the  Circular  on  Relevant  Issues  Concerning  Foreign  Exchange  Administration  for  Domestic  Individuals
Participating in an Employee Share Incentive Plan of an Overseas-Listed Company (which replaced the old Circular 78, “Application Procedure of Foreign
Exchange Administration for Domestic Individuals Participating in an Employee Stock Holding Plan or Stock Option Plan of an Overseas-Listed Company”
promulgated on March 28, 2007), or the New Share Incentive Rule. Under the New Share Incentive Rule, PRC citizens who participate in a share incentive
plan of an overseas publicly listed company are required to register with SAFE and complete certain other procedures. All such participants need to retain a
PRC agent through a PRC subsidiary to register with SAFE and handle foreign exchange matters such as opening accounts, transferring and settlement of the
relevant proceeds. The New Share Incentive Rule further requires that an offshore agent should also be designated to handle matters in connection with the
exercise or sale of share options and proceeds transferring for the share incentive plan participants.

We  and  our  PRC  employees  who  have  been  granted  stock  options  are  subject  to  the  New  Share  Incentive  Rule.  We  are  in  the  process  of  completing  the
registration and procedures which the New Share Incentive Rule requires, but the application documents are subject to the review and approval of SAFE, and
we can make no assurance as to when the registration and procedures could be completed. If we or our PRC employees fail to comply with the New Share
Incentive Rule, we and/or our PRC employees may face sanctions imposed by the foreign exchange authority or any other PRC government authorities.

In addition, the State Administration of Taxation, or SAT, has issued a few circulars concerning employee stock options. Under these circulars, our employees
working in China who exercise stock options will be subject to PRC individual income tax. Our PRC subsidiaries have obligations to file documents related
to  employee  stock  options  with  relevant  tax  authorities  and  withhold  individual  income  taxes  of  those  employees  who  exercise  their  stock  options.  If  our
employees fail to pay and we fail to withhold their income taxes, we may face sanctions imposed by tax authorities or any other PRC government authorities.

Under the SAFE regulations, PRC residents who make, or have previously made, direct or indirect investments in offshore companies, will be required to
register  those  investments.  In  addition,  any  PRC  resident  who  is  a  direct  or  indirect  shareholder  of  an  offshore  company  is  required  to  file  or  update  the
registration with the local branch of the SAFE, with respect to that offshore company, any material change involving its round-trip investment and capital
variation. The PRC subsidiaries of that offshore company are required to urge the PRC resident shareholders to make such updates. If any PRC shareholder
fails to make the required SAFE registration or file or update the registration, the PRC subsidiaries of that offshore parent company may be prohibited from
distributing their profits and the proceeds from any reduction in capital, share transfer or liquidation, to their offshore parent company, and the offshore parent
company may also be prohibited from injecting additional capital into their PRC subsidiaries. Moreover, failure to comply with the various SAFE registration
requirements  described  above  could  result  in  liability  under  PRC  laws  for  evasion  of  applicable  foreign  exchange  restrictions,  such  as  restrictions  on
distributing dividend to our offshore entities or monetary penalties against us. We cannot assure you that all of our shareholders who are PRC residents will
make  or  obtain  any  applicable  registrations  or  approvals  required  by  these  SAFE  regulations.  The  failure  or  inability  of  our  PRC  resident  shareholders  to
comply with these SAFE registration procedures may subject us to fines and legal sanctions, restrict our cross-border investment activities, or limit our PRC
subsidiaries’ ability to distribute dividends to or obtain foreign-exchange-dominated loans from our company.

21

 
 
 
 
 
 
 
 
 
 
As it is uncertain how the SAFE regulations will be interpreted or implemented, we cannot predict how these regulations will affect our business operations or
future  strategy.  For  example,  we  may  be  subject  to  more  stringent  review  and  approval  process  with  respect  to  our  foreign  exchange  activities,  such  as
remittance  of  dividends  and  foreign-currency-denominated  borrowings,  which  may  adversely  affect  our  results  of  operations  and  financial  condition.  In
addition, if we decide to acquire a PRC domestic company, we cannot assure you that we or the owners of such company, as the case may be, will be able to
obtain  the  necessary  approvals  or  complete  the  necessary  filings  and  registrations  required  by  the  SAFE  regulations.  This  may  restrict  our  ability  to
implement our acquisition strategy and could adversely affect our business and prospects.

Certain measures promulgated by the People’s Bank of China on foreign exchange for individuals set forth the respective requirements for foreign exchange
transactions  by  PRC  individuals  under  either  the  current  account  or  the  capital  account.  Implementing  rules  for  these  measures  were  promulgated  by  the
SAFE  which,  among  other  things,  specified  approval  requirements  for  certain  capital  account  transactions  such  as  a  PRC  citizen’s  participation  in  the
employee stock ownership plans or stock option plans of an overseas publicly-listed company. The SAFE also promulgated rules under which PRC citizens
who are granted stock options by an overseas publicly-listed company are required, through a PRC agent or PRC subsidiary of such overseas publicly-listed
company, to register with the SAFE and complete certain other procedures. We and our PRC employees who have been granted stock options are subject to
these rules, and we are in the process of completing the required registration and procedures, but the application documents are subject to the review and
approval of SAFE, and we can make no assurance as to when the registration and procedures could be completed. If we or our PRC optionees fail to comply
with  these  regulations,  we  or  our  PRC  optionees  may  be  subject  to  fines  and  legal  sanctions.  See  “Item  4.  Information  on  the  Company—B.  Business
Overview—Regulation— SAFE Regulations on Offshore Investment by PRC Residents and Employee Stock Options.”

The M&A Rule sets forth complex procedures for acquisitions conducted by foreign investors which could make it more difficult to pursue growth
through acquisitions.

Regulations on Mergers and Acquisitions of Domestic Enterprises by Foreign Investors, or the M&A Rule, sets forth complex procedures and requirements
that  could  make  merger  and  acquisition  activities  by  foreign  investors  more  time-consuming  and  complex.  Part  of  our  growth  strategy  includes  acquiring
complementary businesses or assets. Complying with the requirements of the M&A Rule to complete such transactions could be time-consuming, and any
required approval processes, including obtaining approval from the Ministry of Commerce, may delay or inhibit the completion of such transactions, which
could affect our ability to expand our business or maintain our market share. In addition, if any of our acquisitions were subject to the M&A Rule and were
found not to be in compliance with the requirements of the M&A Rule in the future, relevant PRC regulatory agencies may impose fines and penalties on our
operations in the PRC, limit our operating privileges in the PRC, or take other actions that could materially and adversely affect our business and results of
operations.

Changes in laws and regulations governing air travel advertising or otherwise affecting our business in China may result in substantial costs and
diversion of resources and may materially and adversely affect our business and results of operations.

There  are  no  existing  PRC  laws  or  regulations  that  specifically  define  or  regulate  air  travel  advertising.  Changes  in  existing  laws  and  regulations  or  the
implementation of new laws and regulations governing the content of air travel advertising and our business licenses or otherwise affecting our business in
China may result in substantial costs and diversion of resources and may materially and adversely affect our business prospects and results of operations.

The  enforcement  of  the  Labor  Contract  Law  and  other  labor-related  regulations  in  China  may  adversely  affect  our  business  and  our  results  of
operations.

The Labor Contract Law, which came into effect January 1, 2008 and was amended on July 1, 2013, established more restrictions and increased costs for
employers  to  dismiss  employees  under  certain  circumstances,  including  specific  provisions  relating  to  fixed-term  employment  contracts,  non-fixed-term
employment contracts, task-based employment, part-time employment, probation, consultation with the labor union and employee representative’s council,
employment without a contract, dismissal of employees, compensation upon termination and for overtime work, and collective bargaining. Under the Labor
Contract Law, unless otherwise provided by law, an employer is obligated to sign a labor contract with a non-fixed term with an employee, if the employer
continues  to  hire  the  employee  after  the  expiration  of  two  consecutive  fixed-term  labor  contracts,  or  if  the  employee  has  worked  for  the  employer  for  10
consecutive years. Severance pay is required if a labor contract expires and is not renewed because of the employer’s refusal to renew or seeking to renew
with less favorable terms. In addition, under the Regulations on Paid Annual Leave for Employees, which became effective on January 1, 2008, employees
who have served more than one year for an employer are entitled to a paid vacation for five to 15 days, depending on the employee’s number of years of
employment. Employees who waive such vacation at the request of employers are entitled to compensation that equals to three times their regular daily salary
for each waived vacation day. As a result of these new labor protection measures, our labor costs are expected to increase, which may adversely affect our
business and our results of operations. It is also possible that the PRC government may enact additional labor-related legislations in the future, which would
further increase our labor costs and affect our operations.

22

 
 
 
 
 
 
 
 
 
 
 
 
We have limited insurance coverage in China, and any business disruption or litigation we experience may result in our incurring substantial costs
and the diversion of resources.

Insurance  companies  in  China  offer  limited  business  insurance  products  and  do  not,  to  our  knowledge,  offer  business  liability  insurance.  While  business
disruption  insurance  is  available  to  a  limited  extent  in  China,  we  have  determined  that  the  risks  of  disruption,  cost  of  such  insurance  and  the  difficulties
associated  with  acquiring  such  insurance  on  commercially  reasonable  terms  make  it  impractical  for  us  to  have  such  insurance.  As  a  result,  except  for  our
liability insurance for directors and officers, we do not have any business liability, disruption or litigation insurance coverage for our operations in China. Any
business disruption or litigation may result in our incurring substantial costs and the diversion of resources.

We may have claims and lawsuits against us that may result in material adverse outcomes.

We have been and will be possibly subject to a variety of claims and lawsuits. See “Item 8. Financial Information—A. Consolidated Statements and Other
Financial  Information—Legal  Proceedings.”  This  litigation  and  other  claims  that  may  be  made  against  us  from  time  to  time  are  subject  to  inherent
uncertainties. Adverse outcomes in one or more of those claims may result in significant monetary damages or injunctive relief that could adversely affect our
ability to conduct our business. A material adverse impact on our financial statements also could occur for the period in which the effect of an unfavorable
final outcome becomes probable and reasonably estimable.

If one or more of our PRC subsidiaries fails to maintain or obtain qualifications to receive PRC preferential tax treatments, we will be required to
pay more taxes, which may have a material adverse effect on our result of operations.

The EIT Law (revised in 2017), which became effective on February 24, 2017, imposes a uniform income tax rate of 25% on most domestic enterprises and
foreign investment enterprises. Under this law, entities that qualify as “high and new technology enterprises strongly supported by the state,” or HNTE, are
entitled  to  the  preferential  EIT  rate  of  15%.  A  company’s  status  as  a  HNTE  is  valid  for  three  years,  after  which  the  company  must  re-apply  for  such
qualification in order to continue to enjoy the preferential EIT rate. In addition, according to relevant guidelines, “new software enterprises” can enjoy an
income tax exemption for two years beginning with their first profitable year and a 50% tax reduction to a rate of 12.5% for the subsequent three years.

In September 2011, one of our PRC subsidiaries, Chuangyi Technology received the HNTE certificate, and, Chuangyi Technology successfully renewed its
HNTE status and obtained the renewed certificate issued by the competent governmental authority successively in October 2014 and December 2017. As a
result, Chuangyi Technology was subject to an EIT rate of 15% from 2014 to 2017, and is subject to an EIT rate of 25% from 2018.

Xi’an  AirMedia  Chuangyi  Technology  Co.,  Ltd.,  one  of  our  PRC  subsidiaries,  or  Xi’an  Shengshi,  received  the  HNTE  certificate  jointly  issued  by  the
competent  governmental  authorities  in  Shanxi  Province  in  September  2014.  As  such,  Xi’an  Shengshi  enjoyed  a  preferential  income  tax  rate  of  15%  from
2014 to 2016. Xi’an Shengshi is subject to EIT at a rate of 25% from 2017 afterwards.

23

 
 
 
 
 
 
 
 
 
 
 
 
Shenzhen  AirMedia  Information  Technology  Co.,  Ltd.,  one  of  our  PRC  subsidiaries,  or  Shenzhen  Yuehang  is  subject  to  EIT  at  a  rate  of  25%  from  2013
afterwards.

We cannot assure you that our PRC subsidiaries will be able to maintain or obtain qualifications to receive the above preferential tax treatments; we will be
required  to  pay  more  taxes  if  they  fail  to  become  or  continue  to  be  eligible  to  receive  PRC  tax  benefits,  which  may  materially  and  adversely  affect  our
business and results of operations.

Dividends payable to us by our wholly-owned operating subsidiaries may be subject to PRC withholding taxes, or we may be subject to PRC taxation
on our worldwide income, and dividends distributed to our investors may be subject to more PRC withholding taxes under PRC tax law.

Under  the  EIT  Law  and  related  regulations,  dividends  payable  by  a  foreign-invested  enterprise  in  China  to  its  foreign  investors  who  are  non-resident
enterprises are subject to a 10% withholding tax, unless any such foreign investor’s jurisdiction of incorporation has a tax treaty with China that provides for a
different  withholding  arrangement.  The  British  Virgin  Islands,  or  BVI,  where  Broad  Cosmos  Enterprises  Ltd.,  or  Broad  Cosmos,  our  wholly-owned
subsidiary, is incorporated, does not have such a tax treaty with AN China, the 100% shareholder of Chuangyi Technology, Shenzhen Yuehang and Xi’an
Shengshi,  is  incorporated  in  Hong  Kong.  According  to  the  Mainland  and  Hong  Kong  Special Administrative  Region  Arrangement  on  Avoiding  Double
Taxation or Evasion of Taxation on Income between China and Hong Kong and the relevant rules, dividends paid by a foreign-invested enterprise in China to
its direct holding company in Hong Kong will be subject to withholding tax at a rate of 5% (if the foreign investor owns directly at least 25% of the shares of
the  foreign-invested  enterprise).  However,  under  recently  implemented  PRC  regulations,  now  our  Hong  Kong  subsidiary  must  obtain  approval  from  the
competent local branch of the State Administration of Taxation in accordance with the double-taxation agreement among the PRC and Hong Kong in order to
enjoy the 5% preferential withholding tax rate. In February 2009, the State Administration of Taxation issued Notice No. 81. According to Notice No. 81, in
order to enjoy the preferential treatment on dividend withholding tax rates, an enterprise must be the “beneficial owner” of the relevant dividend income, and
no  enterprise  is  entitled  to  enjoy  preferential  treatment  pursuant  to  any  tax  treaties  if  such  enterprise  qualifies  for  such  preferential  tax  rates  through  any
transaction  or  arrangement,  the  major  purpose  of  which  is  to  obtain  such  preferential  tax  treatment.  The  tax  authority  in  charge  has  the  right  to  make
adjustments to the applicable tax rates, if it determines that any taxpayer has enjoyed preferential treatment under tax treaties as a result of such transaction or
arrangement.  In  October  2009,  the  State  Administration  of  Taxation  issued  another  notice  on  this  matter,  or  Notice  No.  601,  to  provide  guidance  on  the
criteria to determine whether an enterprise qualifies as the “beneficial owner” of the PRC sourced income for the purpose of obtaining preferential treatment
under tax treaties. Pursuant to Notice No. 601, the PRC tax authorities will review and grant tax preferential treatment on a case-by-case basis and adopt the
“substance over form” principle in the review. Notice 601 specifies that a beneficial owner should generally carry out substantial business activities and own
and  have  control  over  the  income,  the  assets  or  other  rights  generating  the  income.  Therefore,  an  agent  or  a  conduit  company  will  not  be  regarded  as  a
beneficial owner of such income. Since the two notices were issued, it has remained unclear how the PRC tax authorities will implement them in practice and
to what extent they will affect the dividend withholding tax rates for dividends distributed by our subsidiaries in China to our Hong Kong subsidiary. If the
relevant tax authority determines that our Hong Kong subsidiary is a conduit company and does not qualify as the “beneficial owner” of the dividend income
it receives from our PRC subsidiaries, the higher 10% withholding tax rate may apply to such dividends. On February 3, 2018, SAT issued Announcement of
the State Administration of Taxation on Issues concerning “Beneficial Owners” in Tax Treaties, or Circular 9, which became effective on April 1, 2018 and
superseded Notice No. 601. In comparison with Notice No. 601, Circular 9 enlarging and further explaining the scope of beneficial owner, supplementing the
applicants  deemed  as  beneficial  owners  who  obtain  proceeds  from  China  as  direct  or  indirect  100%  shareholder,  increasing  the  certainty  of  identifying
beneficial owner.

24

 
 
 
 
 
 
 
 
Under  the  EIT  Law  and  EIT  Implementation  Rules,  an  enterprise  established  outside  of  the  PRC  with  “de  facto  management  bodies”  within  the  PRC  is
considered a PRC resident enterprise and is subject to the EIT at the rate of 25% on its worldwide income. The EIT Implementation Rules define the term “de
facto management bodies” as “establishments that carry out substantial and overall management and control over the manufacturing and business operations,
personnel,  accounting,  properties,  etc.  of  an  enterprise.”  The  SAT  issued  the  Notice  Regarding  the  Determination  of  Chinese-Controlled  Overseas
Incorporated  Enterprises  as  PRC  Tax  Resident  Enterprises  on  the  Basis  of  De  Facto  Management  Bodies,  or  SAT  Circular  82,  on  April  22,  2009.  SAT
Circular  82  provides  certain  specific  criteria  for  determining  whether  the  “de  facto  management  body”  of  a  Chinese-controlled  overseas-incorporated
enterprise is located in China.

In  addition,  the  SAT  issued  a  bulletin  on  July  27,  2011  to  provide  more  guidance  on  the  implementation  of  SAT  Circular  82  with  an  effective  date  to  be
September 1, 2011. The bulletin made clarification in the areas of resident status determination, post-determination administration, as well as competent tax
authorities. It also specifies that when provided with a copy of the Chinese tax resident determination certificate from a resident Chinese controlled offshore
incorporated enterprise, the payer should not withhold 10% income tax when paying the Chinese-sourced dividends, interest, royalties, etc. to the Chinese
controlled offshore incorporated enterprise. Although both SAT Circular 82 and the bulletin only apply to offshore enterprises controlled by PRC enterprises,
not to those that, like our company, are controlled by PRC individuals, the determination criteria set forth in SAT Circular 82 and administration clarification
made in the bulletin may reflect the SAT’s general position on how the “de facto management body” test should be applied in determining the tax residency
status of offshore enterprises and the administration measures that should be implemented, regardless of whether they are controlled by PRC enterprises or
PRC individuals.

After  consulting  with  our  PRC  counsel,  we  do  not  believe  that  our  holding  company  and  other  overseas  subsidiaries  should  be  deemed  PRC  resident
enterprises  as,  among  other  things,  certain  of  our  company’s  key  assets  and  records,  including  register  of  members,  board  resolutions  and  shareholder
resolutions, are located and maintained outside of the PRC, and we also hold our board and board committee meetings outside of the PRC from time to time.
However, we have been advised by our PRC counsel, Commerce & Finance Law Offices, that because there remains uncertainty regarding the interpretation
and  implementation  of  the  EIT  Law  and  EIT  Implementation  Rules,  it  is  uncertain  whether  we  will  be  deemed  a  PRC  resident  enterprise.  If  the  PRC
authorities were to subsequently determine, or any further regulations provide, that we should be treated as a PRC resident enterprise, we would be subject to
a 25% EIT on our global income. To the extent our holding company earns income outside of China, a 25% EIT on our global income may increase our tax
burden and could adversely affect our financial condition and results of operations.

If we are regarded as a PRC resident enterprise, dividends distributed from our PRC subsidiaries to us could be exempt from the PRC dividend withholding
tax, since such income is exempt under the EIT Law and the EIT Implementation Rules to the extent such dividends are deemed “dividends among qualified
PRC  resident  enterprises.”  If  we  are  considered  a  resident  enterprise  for  enterprise  income  tax  purposes,  dividends  we  pay  with  respect  to  our  ADSs  or
ordinary  shares  may  be  considered  income  derived  from  sources  within  the  PRC  and  subject  to  PRC  withholding  tax  of  10%.  In  addition,  non-PRC
shareholders may be subject to PRC tax on gains realized on the sale or other disposition of ADSs or ordinary shares, if such income is treated as sourced
from within the PRC. It is unclear whether our non-PRC shareholders would be able to claim the benefits of any tax treaties between their tax residence and
the PRC in the event that we are considered as a PRC resident enterprise.

With the 10% PRC dividend withholding tax, we will incur an incremental PRC tax cost when we distribute our PRC profits to our ultimate shareholders if
we are deemed not to be a PRC resident enterprise. On the other hand, if we are determined to be a PRC resident enterprise under the EIT Law and receive
income other than dividends, our profitability and cash flow would be adversely impacted due to our worldwide income being taxed in China under the EIT
Law.

Moreover, under the EIT Law, foreign ADS holders may be subject to a 10% withholding tax upon dividends payable by us and gains realized on the sale or
other disposition of ADSs or ordinary shares, if we are classified as a PRC resident enterprise and such income is deemed to be sourced from within the PRC.
Although we are incorporated in the Cayman Islands, it is unclear whether the dividends payable by us or the gains our foreign ADS holders may realize on
disposition will be regarded as income from sources within the PRC if we are classified as a PRC resident enterprise. Any such tax on our dividend payments
will reduce the returns of your investment.

25

 
 
 
 
 
 
 
 
 
 
Scrutiny over acquisition transactions by the PRC tax authorities may have a negative impact on potential acquisitions we may pursue in the future.

In connection with the PRC Enterprise Income Tax Law, or the EIT Law, the Ministry of Finance and the State Administration of Taxation jointly issued, on
April 30, 2009, the Notice on Issues Concerning Process of Enterprise Income Tax in Enterprise Restructuring Business, or Circular 59. On December 10,
2009,  the  State  Administration  of  Taxation  issued  the  Notice  on  Strengthening  the  Management  on  Enterprise  Income  Tax  for  Non-resident  Enterprises
Equity Transfer, or Circular 698. Both Circular 59 and Circular 698 became effective retroactively on January 1, 2008. By promulgating and implementing
these circulars, the PRC tax authorities have enhanced their scrutiny over the direct or indirect transfer of equity interests in a PRC resident enterprise by a
non-resident enterprise. However, SAT issued Announcement of the State Administration of Taxation on Matters concerning Withholding of Income Tax of
Non-resident Enterprises at Source, or Circular 37, which became effective on December 1, 2017 and superseded Circular 698. In comparison with Circular
698,  Circular  37  releases  the  obligations  of  withholding  agent,  taxpayer  by  adopting  straightforward  procedures  and  simple  calculation  concerning
withholding income tax of non-resident enterprises at source.

On February 3, 2015, the SAT issued the Announcement on Several Issues concerning the Enterprise Income Tax on Indirect Transfers of Properties by Non-
Resident  Enterprises,  or  Public  Notice  7,  to  supersede  tax  rules  in  relation  to  the  Indirect  Transfer  of  Shares  under  the  original  SAT  Circular  698.  Public
Notice 7 covers transactions involving not only Indirect Transfer of Shares as set forth under SAT Circular 698 but also transactions involving an overseas
company’s indirect transfer of other property or assets (such as real properties) located in China (collectively, ‘‘PRC Taxable Properties’’) through transfer of
shares  of  an  offshore  intermediary  company.  Pursuant  to  Public  Notice  7,  in  the  event  that  non-residential  enterprises  indirectly  transfer  PRC  Taxable
Properties without reasonable commercial purposes in order to evade PRC enterprise income tax, such indirect transfer will be deemed as direct transfer of
PRC  Taxable  Properties  and,  therefore,  be  subject  to  PRC  enterprise  income  tax.  In  addition,  Public  Notice  7  provides  clearer  criteria  on  how  to  assess
reasonable commercial purposes and allows for safe harbor scenarios applicable to internal group restructurings. Under Public Notice 7, subject to certain
exceptions such as internal group restructurings and purchase and sale of shares of the same publicly-listed oversea enterprise in a public securities market, an
indirect  transfer  of  PRC  Taxable  Properties  shall  be  directly  deemed  as  having  no  reasonable  commercial  purposes  if  the  following  circumstances  are
satisfied: (i) more than 75% of the value of overseas enterprises’ shares directly or indirectly comes from PRC Taxable Properties; (ii) at any time within one
year before the indirect transfer of PRC Taxable Properties, more than 90% the total amount of overseas enterprises’ assets (excluding cash) are directly or
indirectly constituted by their investment within the PRC, or within one year before the indirect transfer of PRC Taxable Properties, more than 90% of the
overseas  enterprises’  income  directly  or  indirectly  derive  from  the  PRC;  (iii)  the  overseas  enterprises  and  their  controlling  enterprises,  which  directly  or
indirectly hold PRC Taxable Properties, cannot justify the economic substance of the corporate structure; and (iv) overseas tax payment regarding indirect
transfer  of  PRC  Taxable  Properties  is  lower  than  PRC  tax  payment  regarding  direct  transfer  of  PRC  Taxable  Properties.  Public  Notice  7  also  brings
uncertainties to the offshore transferor and transferee of the indirect transfer of PRC Taxable Properties as they have to make self-assessment on whether the
transaction  should  be  subject  to  PRC  tax  and  to  file  or  withhold  the  PRC  tax  accordingly. As  a  result,  where  non-resident  investors  were  involved  in  our
private equity financing or share transfer of our company between two or more offshore parties, if such transactions were determined by the tax authorities to
lack reasonable commercial purpose, we and our non-resident investors may become at risk of being taxed under Circular 37 and Public Notice 7 and may be
required to expend valuable resources to comply with Circular 37 and Public Notice 7 or to establish that we should not be taxed under Circular 37 and Public
Notice 7, which may have an adverse effect on our financial condition and results of operations.

The PRC tax authorities have the discretion under Public Notice 7 to make adjustments to the taxable capital gains based on the difference between the fair
value of the equity interests transferred and the cost of investment. We may pursue acquisitions in the future that may involve complex corporate structures. If
we are considered a non-resident enterprise under the PRC Enterprise Income Tax Law and if the PRC tax authorities make adjustments to the taxable income
of the transactions under SAT Circular 59, Circular 37 or Public Notice 7, our income tax costs associated with such potential acquisitions will be increased,
which may have an adverse effect on our financial condition and results of operations. Although Circular 37 requires less scrutiny on withholding income tax
of non-resident enterprises at source, we cannot assure you that the PRC government will not take harsh measures in the future with respect to tax related
regulations over acquisition transactions.

26

 
 
 
 
 
 
 
 
If  we  become  directly  subject  to  the  scrutiny,  criticism  and  negative  publicity  involving  U.S.-listed  Chinese  companies,  we  may  have  to  expend
significant resources to investigate and resolve the matter which could harm our business operations, stock price and reputation and could result in a
loss of your investment in our stock, especially if such matter cannot be addressed and resolved favorably.

Occasionally, U.S. public companies that have substantially all of their operations in China, particularly companies which have completed so-called reverse
merger transactions, have been the subject of intense scrutiny, criticism and negative publicity by investors, financial commentators and regulatory agencies,
such as the SEC. Much of the scrutiny, criticism and negative publicity has centered around financial and accounting irregularities and mistakes, a lack of
effective internal controls over financial accounting, inadequate corporate governance policies or a lack of adherence thereto and, in many cases, allegations
of fraud. For example, in December 2012, the SEC initiated administrative proceedings against the China affiliates of the Big Four public accounting firms
for  allegedly  refusing  to  produce  audit  work  papers  and  other  documents  related  to  certain  China-based  companies  under  investigation  by  the  SEC  for
potential accounting fraud against U.S. investors. Although the firms reached a settlement with the SEC and although we were not and are not subject to any
ongoing SEC investigations, many U.S. listed Chinese companies are now subject to, or may become subject to, shareholder lawsuits and SEC enforcement
actions  and  are  conducting  internal  and  external  investigations  into  the  allegations.  As  a  result  of  this  proceeding  and  the  scrutiny,  criticism  and  negative
publicity, the publicly traded stock of many U.S. listed Chinese companies has sharply decreased in value and, in some cases, has become virtually worthless.
It is not clear what effect this sector-wide scrutiny, criticism and negative publicity will have on our Company, our business and our stock price. If we become
the subject of any unfavorable allegations, whether such allegations are proven to be true or untrue, we will have to expend significant resources to investigate
such allegations and/or defend our company. This situation will be costly and time consuming and distract our management from growing our company.

Our  prior  audit  reports  are  prepared  by  auditor  who  is  not  inspected  by  the  Public  Company  Accounting  Oversight  Board  and,  as  such,  you  are
deprived of the benefits of such inspection.

Deloitte  Touche  Tohmatsu  Certified  Public Accountants  LLP  (Deloitte),  which  acted  as  our  independent  registered  public  accounting  firm  until  March  3,
2017, issued audit reports included in our prior annual reports filed with the United States Securities and Exchange Commission. Auditors of companies that
are  traded  publicly  in  the  United  States  and  a  firm  registered  with  the  Public  Company  Accounting  Oversight  Board  (United  States),  or  the  PCAOB,  are
required by the laws of the United States to undergo regular inspections by the PCAOB to assess their compliance with the laws of the United States and
professional  standards.  Because  Deloitte  is  located  in  the  Peoples’  Republic  of  China,  a  jurisdiction  where  the  PCAOB  is  currently  unable  to  conduct
inspections without the approval of the Chinese authorities, they are not currently inspected by the PCAOB. On December 7, 2018, the SEC and the PCAOB
issued a joint statement highlighting continued challenges faced by the U.S. regulators in their oversight of financial statement audits of U.S.-listed companies
with significant operations in China.  The joint statement reflects a heightened interest in an issue that has vexed U.S. regulators in recent years.  However, it
remains unclear what further actions the SEC and PCAOB will take to address the problem. 

Inspections  of  other  firms  that  the  PCAOB  has  conducted  outside  China  have  identified  deficiencies  in  those  firms’  audit  procedures  and  quality  control
procedures, which may be addressed as part of the inspection process to improve future audit quality. This lack of PCAOB inspections in China prevents the
PCAOB  from  regularly  evaluating  Deloitte’s  audits  and  its  quality  control  procedures.  As  a  result,  investors  may  be  deprived  of  the  benefits  of  PCAOB
inspections.

The inability of the PCAOB to conduct inspections of auditors in China makes it more difficult to evaluate the effectiveness of Deloitte’s audit procedures or
quality control procedures as compared to auditors outside of China that are subject to PCAOB inspections. Investors may lose confidence in our reported
financial information and procedures and the quality of our financial statements issued by Deloitte.

27

 
 
 
 
 
 
 
 
 
 
If  additional  remedial  measures  are  imposed  on  the  “Big  Four”  PRC-based  accounting  firms,  including  Deloitte,  our  previous  independent
registered public accounting firm, in administrative proceedings brought by the SEC alleging the firms’ failure to meet specific criteria set by the
SEC, with respect to requests for the production of documents, investors’ confidence in our reported financial information and the price of our ADSs
could be adversely affected.

Starting in 2011, the Chinese affiliates of the “big four” accounting firms, including Deloitte, our previous independent registered public accounting firm,
were affected by a conflict between the United States’ and Chinese laws. Specifically, for certain U.S. listed companies operating and audited in mainland
China, the SEC and the PCAOB sought to obtain from these Chinese accounting firms access to their audit work papers and related documents. The firms
were, however, advised and directed that under China law they could not respond directly to the U.S. regulators on those requests, and that requests by foreign
regulators for access to such papers in China had to be channeled through the China Securities Regulatory Commission, or the CSRC.

In late 2012, this impasse led the SEC to commence administrative proceedings under Rule 102(e) of its Rules of Practice and also under the Sarbanes-Oxley
Act of 2002 against the Chinese accounting firms, including Deloitte. A first instance trial of the proceedings in July 2013 in the SEC’s internal administrative
court resulted in an adverse judgment against the firms. The administrative law judge proposed penalties on the firms including a temporary suspension of
their right to practice before the SEC, although such proposed penalties did not take effect pending review by the Commissioners of the SEC. On February 6,
2015, before a review by the Commissioner had taken place, the firms reached a settlement with the SEC. Under the settlement, the SEC accepts that future
requests by the SEC for the production of documents will normally be made to the CSRC. The firms will receive matching Section 106 requests, and are
required to abide by a detailed set of procedures with respect to such requests, which in substance require them to facilitate production via the CSRC. If they
fail to meet the specified criteria, the SEC retains authority to impose a variety of additional remedial measures on the firms, depending on the nature of the
failure. Under the terms of the settlement, the underlying proceeding against the four PRC-based accounting firms was deemed dismissed with prejudice at
the end of four years starting from the settlement date, which was February 6, 2019. We cannot predict if the SEC will further challenge the four PRC-based
accounting firms’ compliance with U.S. law in connection with U.S. regulatory requests for audit work papers or if the results of such a challenge would
result in the SEC imposing penalties such as suspensions.

In the event that the SEC restarts the administrative proceedings, depending upon the final outcome, listed companies in the United States with major PRC
operations  may  find  it  difficult  or  impossible  to  retain  auditors  in  respect  of  their  operations  in  the  PRC,  which  could  result  in  financial  statements  being
determined to not be in compliance with the requirements of the Exchange Act and possible delisting. Moreover, any negative news about any such future
proceedings  against  these  audit  firms  may  cause  investor  uncertainty  regarding  China-based,  United  States-listed  companies  and  the  market  price  of  our
ADSs may be adversely affected.

RISKS RELATED TO THE MARKET FOR OUR ADSs

If the buyers of our equity interest in AM Advertising exercise their respective revocation rights and require us to repurchase the equity interest sold
or if we need to compensate the buyers as earnout, our business and financial results may experience material adverse effect.

In June 2015, we entered into an equity interest transfer agreement with Beijing Longde Wenchuang Investment Fund Management Co., Ltd. to sell 75%
equity  interest  of  AM Advertising  for  RMB2.1  billion  in  cash.  In  November  2015,  Beijing  Longde  Wenchuang  Investment  Fund  Management  Co.,  Ltd.
assigned and transferred its rights and obligations under the equity interest transfer agreement relating to 46.43% equity interest of AM Advertising to Beijing
Cultural Center Construction and Development Fund (Limited Partnership). We have completed the equity interest transfer and have received the payments
for the transfer. However, under that equity interest transfer agreement, the buyers may require us to repurchase the 75% equity interest upon the occurrence
of certain events. In addition, the agreement’s earnout provisions will continue to apply until all profit targets have been achieved. See “Item 4. Information
on the Company—A. History and Development of the Company.” On March 28, 2018, August 23, 2018 and November 2018, we entered into a memorandum
of understanding (MoU) and its supplemental agreement respectively, with, among others, Beijing Longde Wenchuang Investment Fund Management Co.,
Ltd and Beijing Cultural Center Construction and Development Fund (Limited Partnership), under which, among other things, Linghang Shengshi, Mr. Guo
and Mr. Xu have agreed to pay or make available to AM Advertising on or prior to May 30, 2018 and further extended to September 30, 2018 and December
31, 2018 an aggregate of RMB304,553,900 to hedge the following amounts (i) the RMB152,000,000 profits attributable to Linghang Shengshi, Mr. Guo and
Mr. Xu for the first nine months of 2015, based on a third-party pro forma audit report on the Target Business; (ii) the loan of RMB88,000,000 in principal
balance and RMB7,840,000 in interests; and (iii) the payment of RMB56,713,900 in cash after the sale of the 20.32% equity interests in AM Advertising,
which  consisted  of  20.18%  equity  interests  hold  by  the  Company  and  0.14%  equity  interests  hold  by  Mr.  Man  Guo  and  Mr.  Qing  Xu  on  behalf  of  the
Company, and following the completion of the foregoing arrangements, our obligations with respect to the profit target for 2015, the earnout provision for the
first nine months of 2015 and the loans between AM Advertising and Linghang Shengshi shall be deem completed. We are negotiating for further extension
of deadline for payment under the MoU and its supplemental agreement. We cannot assure you that the buyers will not bring up any claim with respect to the
above arrangements and if there is any dispute or legal proceedings initiated, our business and financial position may be adversely affected. 

28

 
 
 
 
 
 
 
 
 
 
 
In  November  2018,  Linghang  Shengshi,  Mr.  Guo  and  Mr.  Xu  entered  into  an  equity  transfer  agreement  with  Jiangsu  Hongzhou  Investment  Co.,  Ltd.,  an
independent third party to sell all the remaining 20.32% equity interest of AM Advertising for an initial transfer price of RMB580 million in cash. We have
completed  the  equity  interest  transfer  and  have  received  the  installment  payment  of  RMB  200  million  for  the  transfer  pursuant  to  this  equity  transfer
agreement.  However,  under  this  equity  transfer  agreement,  the  buyer  may  require  sellers  to  repurchase  the  20.32%  equity  interest  upon  the  occurrence  of
certain events. 

The trading price of our ADSs has been and may continue to be volatile.

The trading price of our ADSs has been and may continue to be subject to wide fluctuations. During the year of 2018, the trading prices of our ADSs on the
Nasdaq Global Select Market and Nasdaq Capital Market ranged from $0.9 to $7.5 per ADS, and the last reported trading price on April 29, 2019 was $1.83
per ADS. Effective on April 11, 2019, we adjusted the ratio of our ADSs to ordinary shares from one ADS representing two ordinary shares to one ADS
representing ten ordinary shares. The aforementioned trading prices have not been adjusted for the ADS ratio change. The price of our ADSs may fluctuate in
response to a number of events and factors including, changes in the economic performance or market valuations of other advertising companies, conditions
in the air travel advertising industry and the sales or perceived potential sales of additional ordinary shares or ADSs.

In  addition,  the  securities  market  has  from  time  to  time  experienced  significant  price  and  volume  fluctuations  unrelated  to  the  operating  performance  of
particular companies. These market fluctuations may also have a material adverse effect on the market price of our ADSs.

Additional sales of our ordinary shares in the public market, or the perception that these sales could occur, could also cause the market price of our ADSs to
decline.

We  have  been  named  as  a  defendant  or  respondent  in  legal  proceedings  that  could  have  a  material  adverse  impact  on  our  business,  financial
condition, results of operation, cash flows and reputation.

We  will  have  to  defend  against  the  legal  proceedings  described  in  “Item  8.  Financial  Information—A.  Consolidated  Statements  and  Other  Financial
Information—Legal  Proceedings,”  including  any  appeals  of  such  legal  proceedings  should  our  initial  defense  be  unsuccessful.  We  are  currently  unable  to
estimate the possible loss or possible range of loss, if any, associated with the resolution of these legal proceedings. In the event that our initial defense of
these  legal  proceedings  is  unsuccessful,  there  can  be  no  assurance  that  we  will  prevail  in  any  appeal.  Any  adverse  outcome  of  these  cases,  including  any
plaintiff’s or claimant’s appeal of a judgment in these legal proceedings, could have a material adverse effect on our business, financial condition, results of
operation,  cash  flows  and  reputation.  In  addition,  there  can  be  no  assurance  that  our  insurance  carriers  will  cover  all  or  part  of  the  defense  costs,  or  any
liabilities that may arise from these matters. The legal proceeding process may utilize a significant portion of our cash resources and divert management’s
attention from the day-to-day operations of our company, all of which could harm our business. We also may be subject to claims for indemnification related
to these matters, and we cannot predict the impact that indemnification claims may have on our business or financial results.

29

 
 
 
 
 
 
 
 
 
 
 
You may not have the same voting rights as the holders of our ordinary shares and may not receive voting materials in time to be able to exercise your
right to vote.

Except as described in this annual report and in the deposit agreement, holders of our ADSs will not be able to exercise voting rights attaching to the shares
evidenced by our ADSs on an individual basis. Holders of our ADSs will appoint the depositary or its nominee as their representative to exercise the voting
rights attaching to the shares represented by the ADSs. You may not receive voting materials in time to instruct the depositary to vote, and it is possible that
you, or persons who hold their ADSs through brokers, dealers or other third parties, will not have the opportunity to exercise a right to vote.

Your  right  to  participate  in  any  future  rights  offerings  may  be  limited,  which  may  cause  dilution  to  your  holdings  and  you  may  not  receive  cash
dividends if it is impractical to make them available to you.

We may from time to time distribute rights to our shareholders, including rights to acquire our securities. However, we cannot make rights available to you in
the United States unless we register both the rights and the securities to which the rights relate under the U.S. Securities Act of 1933, as amended, or the
Securities  Act,  or  an  exemption  from  the  registration  requirements  is  available.  Under  the  deposit  agreement,  the  depositary  bank  will  not  make  rights
available to you unless both the rights and the underlying securities to be distributed to ADS holders are either registered under the Securities Act or exempt
from  registration  under  the  Securities  Act.  We  are  under  no  obligation  to  file  a  registration  statement  with  respect  to  any  such  rights  or  securities  or  to
endeavor to cause such a registration statement to be declared effective and we may not be able to establish a necessary exemption from registration under the
Securities Act. Accordingly, you may be unable to participate in our rights offerings and may experience dilution in your holdings.

The depositary of our ADSs has agreed to pay to you the cash dividends or other distributions it or the custodian receives on our ordinary shares or other
deposited  securities  after  deducting  its  fees  and  expenses.  You  will  receive  these  distributions  in  proportion  to  the  number  of  ordinary  shares  your ADSs
represent. However, the depositary may, at its discretion, decide that it is inequitable or impractical to make a distribution available to any holders of ADSs.
For example, the depositary may determine that it is not practicable to distribute certain property through the mail, or that the value of certain distributions
may be less than the cost of mailing them. In these cases, the depositary may decide not to distribute such property to you.

You may be subject to limitations on transfer of your ADSs.

Your ADSs are transferable on the books of the depositary. However, the depositary may close its transfer books at any time or from time to time when it
deems expedient in connection with the performance of its duties.

In addition, the depositary may refuse to deliver, transfer or register transfers of ADSs generally when our books or the books of the depositary are closed, or
at any time if we or the depositary deem it advisable to do so because of any requirement of law or of any government or governmental body, or under any
provision of the deposit agreement, or for any other reason.

You may face difficulties in protecting your interests, and your ability to protect your rights through the U.S. federal courts may be limited, because
we are incorporated under Cayman Islands law, conduct substantially all of our operations in China and most of our directors and officers reside
outside the United States.

We are incorporated in the Cayman Islands, and conduct substantially all of our operations in China through our subsidiaries and VIEs. Most of our directors
and officers reside outside the United States and a substantial portion of their assets are located outside of the United States. As a result, it may be difficult for
you to effect service of process within the United States and bring an action against us or against these individuals in a U.S. court if you believe that your
rights have been infringed under the securities laws or otherwise. Even if you are successful in bringing an action of this kind, the laws of the Cayman Islands
and of China may render you unable to enforce a judgment against our assets or the assets of our directors and officers. There is no statutory recognition in
the Cayman Islands of judgments obtained in the United States, although the courts of the Cayman Islands will in certain circumstances recognize and enforce
a non-penal judgment of a foreign court of competent jurisdiction without retrial on the merits.

30

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Our corporate affairs are governed by our amended and restated memorandum and articles of association, as amended and restated from time to time, and by
the Companies Law (2018 Revision) and common law of the Cayman Islands. The rights of shareholders to take legal action against us and our directors,
actions by minority shareholders and the fiduciary duties of our directors are to a large extent governed by the common law of the Cayman Islands. The rights
of  our  shareholders  and  the  fiduciary  duties  of  our  directors  under  Cayman  Islands  law  are  not  as  clearly  established  as  they  would  be  under  statutes  or
judicial precedents in the United States. In particular, the Cayman Islands has a less developed body of securities laws than the United States and provides
significantly  less  protection  to  investors.  In  addition,  Cayman  Islands  companies  may  not  have  standing  to  initiate  a  shareholder  derivative  action  in  U.S.
federal courts.

As a result, our public shareholders may have more difficulty in protecting their interests through actions against us, our management, our directors or our
controlling shareholders than shareholders of a corporation incorporated in a jurisdiction in the United States.

Our memorandum and articles of association contain anti-takeover provisions that could adversely affect the rights of holders of our ordinary shares
and ADSs.

We have included certain provisions in our memorandum and articles of association that could limit the ability of others to acquire control of our company
and deprive our shareholders of the opportunity to sell their shares at a premium over the prevailing market price by discouraging third parties from seeking to
obtain control of our company in a tender offer or similar transactions. The following provisions in our articles may have the effect of delaying or preventing
a change of control of our company:

·

·

Our board of directors has the authority to establish from time to time one or more series of preferred shares without action by our shareholders and
to determine, with respect to any series of preferred shares, the terms and rights of that series, including the designation of the series, the number of
shares  of  the  series,  the  dividend  rights,  dividend  rates,  conversion  rights,  voting  rights,  and  the  rights  and  terms  of  redemption  and  liquidation
preferences.  

Subject to applicable regulatory requirements, our board of directors may issue additional ordinary shares or rights to acquire ordinary shares without
action by our shareholders to the extent of available authorized but unissued shares. 

Our  corporate  actions  are  substantially  controlled  by  our  principal  shareholders  who  could  exert  significant  influence  over  important  corporate
matters, which may reduce the price of our ADSs and deprive you of an opportunity to receive a premium for your shares.

Certain  principal  shareholders  hold  a  substantial  percentage  of  the  outstanding  shares  of  our  company.  For  example,  as  of  March  31,  2019,  our  principal
shareholder, Mr. Herman Man Guo, along with his wife, Ms. Dan Shao, beneficially owned approximately 34.7% of our outstanding ordinary shares. Mr. Guo
and other principal shareholders of our company could exert substantial influence over matters such as electing directors and approving material mergers,
acquisitions or other business combination transactions. This concentration of ownership may also discourage, delay or prevent a change in control of our
company,  which  could  have  the  dual  effect  of  depriving  our  shareholders  of  an  opportunity  to  receive  a  premium  for  their  shares  as  part  of  a  sale  of  our
company and reducing the price of our ADSs. These actions may be taken even if they are opposed by our other shareholders.

We are a “foreign private issuer,” and have disclosure obligations that are different from those of U.S. domestic reporting companies so you should
not expect to receive the same information about us at the same time as a U.S. domestic reporting company may provide.

We  are  a  foreign  private  issuer  and,  as  a  result,  we  are  not  subject  to  certain  of  the  requirements  imposed  upon  U.S.  domestic  issuers  by  the  SEC.  For
example, we are not required by the SEC or the federal securities laws to issue quarterly reports or proxy statements with the SEC. We are required to file our
annual report within four months of our fiscal year end. We are not required to disclose certain detailed information regarding executive compensation that is
required from U.S. domestic issuers. Further, our directors and executive officers are not required to report equity holdings under Section 16 of the Securities
Act. We are also exempt from the requirements of Regulation FD (Fair Disclosure) which, generally, are meant to ensure that select groups of investors are
not privy to specific information about an issuer before other investors. We are, however, still subject to the anti-fraud and anti-manipulation rules of the SEC,
such  as  Rule  10b-5.  Since  many  of  the  disclosure  obligations  required  of  us  as  a  foreign  private  issuer  are  different  from  those  required  by  other  U.S.
domestic reporting companies, our shareholders should not expect to receive information about us in the same amount and at the same time as information is
received from, or provided by, other U.S. domestic reporting companies. We are liable for violations of the rules and regulations of the SEC which do apply to
us as a foreign private issuer. Violations of these rules could affect our business, results of operations and financial condition.

31

 
 
 
 
 
 
 
 
 
 
 
 
 
 
We believe we were a passive foreign investment company for our taxable year ended December 31, 2018, which could subject United States investors
in the ADSs or ordinary shares to significant adverse United States income tax consequences.

Based on the market price of our ADSs and composition of our assets (in particular the retention of a substantial amount of cash), we believe that we were a
“passive foreign investment company,” or “PFIC,” for U.S. federal income tax purposes for our taxable year ended December 31, 2018, and we will likely be
a PFIC for our current taxable year ending December 31, 2019 unless the market price of our ADSs increases and/or we invest a substantial amount of cash
and other passive assets we hold in assets that produce or are held for the production of non-passive income. A non-U.S. corporation will be considered a
PFIC for any taxable year if either (1) 75% or more of its gross income for such year consists of certain types of “passive” income or (2) 50% or more of the
average quarterly value of its assets (as generally determined on the basis of fair market value) during such year produce or are held for the production of
passive income.

If  we  were  to  be  classified  as  a  PFIC  in  any  taxable  year,  a  U.S.  Holder  (as  defined  in  Item  10.  Additional  Information—E.  —Taxation—United  States
Federal  Income  Taxation)  may  incur  significantly  increased  United  States  income  tax  on  gain  recognized  on  the  sale  or  other  disposition  of  the  ADSs  or
ordinary shares and on the receipt of distributions on the ADSs or ordinary shares to the extent such gain or distribution is treated as an “excess distribution”
under the U.S. federal income tax rules. Furthermore, a U.S. Holder will generally be treated as holding an equity interest in a PFIC in the first taxable year of
the U.S. Holder’s holding period in which we become a PFIC and subsequent taxable years even if, we, in fact, cease to be a PFIC in subsequent taxable
years. Accordingly, a U.S. Holder of our ADSs or ordinary shares is urged to consult its tax advisor concerning the U.S. federal income tax consequences of
an  investment  in  our  ADSs  or  ordinary  shares,  including  the  possibility  of  making  a  “mark-to-market”  election.  For  more  information,  see  “Item  10.
Additional Information – E. Taxation – United States Federal Income Taxation.

ITEM 4.

INFORMATION ON THE COMPANY

A.

History and Development of the Company

We were incorporated in the Cayman Islands on April 12, 2007 and conducted our operations in China through our subsidiaries, consolidated VIEs and the
VIEs’ subsidiaries. We commenced operations in August 2005 in China through Linghang Shengshi, a consolidated variable interest entity of our principal
subsidiary, Chuangyi Technology. Later, we established additional PRC consolidated VIEs to conduct our operations in China. Substantially all of our current
operations are conducted through contractual arrangements with these VIEs.

On November 7, 2007, we listed our ADSs on the Nasdaq Global Market under the symbol “AMCN”. We and certain of our then shareholders completed the
initial public offering of 17,250,000 ADSs, representing 34,500,000 of our ordinary shares, on November 13, 2007. Our ADSs were subsequently transferred
to the Nasdaq Global Select Market. Our ADSs, each representing ten of our ordinary shares effective on April 11, 2019, has been transferred to The Nasdaq
Capital Market in November 2018.

During 2014 and 2015, we dissolved certain non-operating holding entities, including Glorious Star Investment Limited, Dominant City Ltd. and Easy Shop
Limited.

In 2015, we sold all equity interest of Jinsheng Advertising, the operating entity of our TV-attached digital frames business. In connection with such equity
interest  transfer,  we  have  transferred  all  relevant  assets,  liabilities  and  managerial  duties  related  to  the  TV-attached  digital  frames  operated  by  Jinsheng
Advertising with net carrying value of $1.1 million. In 2015, we also divested our digital TV screens in airports and did not renew the relevant concession
right contracts as they expired. As a result, we ceased our operation of the business line of digital TV screens in airports.

32

 
 
 
 
 
 
 
 
 
 
 
 
 
In June 2015, we entered into an equity interest transfer agreement with Beijing Longde Wenchuang Investment Fund Management Co., Ltd. to sell 75%
equity  interest  of  AM  Advertising,  for  a  consideration  of  RMB2.1  billion  in  cash.  In  November  2015,  Beijing  Longde  Wenchuang  Investment  Fund
Management Co., Ltd. assigned and transferred its rights and obligations under the equity interest transfer agreement relating to 46.43% equity interest of AM
Advertising to Beijing Cultural Center Construction and Development Fund (Limited Partnership). As part of the transaction, we effected an internal business
reorganization and transferred all our media business in airports (excluding digital TV screens in airports and TV-attached digital frames) and all billboard
and LED media business outside of airports (excluding gas station media network and digital TV screens on airplanes) to AM Advertising to form the target
business to be sold (the “Disposed Business”) and transferred our other business out of AM Advertising. To effectuate the sale, we removed the VIE structure
with respect to AM Advertising. The change in the equity ownership of AM Advertising was registered with the local branch of the State Administration for
Industry and Commerce, or the SAIC (which has merged into the State Administration for Market Regulation, or the SAMR, in March 2018), in December
2015. We have ceased to consolidate the results of AM Advertising after the sale. The buyers may require the Company to repurchase the equity interest of
AM Advertising upon the occurrence of any of the following events:

·

·

·

the audited net profit (before or after adjustment for non-recurring gains and losses, whichever is less) in relation to the Target Business is less than
RMB150 million in 2015;  

eighty per cent of the concession right contracts (as calculated based on the contract subject amount) with respect to the Target Business in the area
of the Beijing Capital Airport effective as of the date of the equity interest transfer agreement which were entered into by AirMedia Advertising,
AirMedia and any of its subsidiaries and/or VIE companies (as set forth in detail in Schedule 6 hereto) are not renewed with AirMedia Advertising
as a party to the contract upon the expiration of the respective contracts; and 

the internal restructuring as required under the equity interest transfer agreement has not been fully completed by June 30, 2016.  

In  addition,  the  agreement’s  earnout  provisions  will  continue  to  apply  until  all  profit  targets  are  achieved.  In  the  event  the  adjusted  net  profit  of  AM
Advertising after the provided restructuring in 2015, 2016 and 2017 is less than the profit target provided for in the agreement, we, as a shareholder of AM
Advertising, will be obligated to compensate the buyers for the deficiency by nil-consideration equity interest transfers or other means of compensation. On
March 28, 2018, August 23, 2018 and November 2018, we entered into a memorandum of understanding (MoU) and its supplemental agreement respectively,
with, among others, Beijing Longde Wenchuang Investment Fund Management Co., Ltd and Beijing Cultural Center Construction and Development Fund
(Limited Partnership), under which, among other things, Linghang Shengshi, Mr. Guo and Mr. Xu have agreed to pay or make available to AM Advertising
on or prior to May 30, 2018 and further extended to September 30, 2018 and December 31, 2018 an aggregate of RMB304,553,900 to hedge the following
amounts (i) the RMB152,000,000 profits attributable to Linghang Shengshi, Mr. Guo and Mr. Xu for the first nine months of 2015, based on a third-party pro
forma  audit  report  on  the  Target  Business;  (ii)  the  loan  of  RMB88,000,000  in  principal  balance  and  RMB7,840,000  in  interests;  and  (iii)  the  payment  of
RMB56,713,900 in cash after the sale of the 20.32% equity interests in AM Advertising, which consisted of 20.18% equity interests hold by the Company
and 0.14% equity interests hold by Mr. Man Guo and Mr. Qing Xu on behalf of the Company, and following the completion of the foregoing arrangements,
our obligations with respect to the profit target for 2015, the earnout provision for the first nine months of 2015 and the loans between AM Advertising and
Linghang  Shengshi  shall  be  deem  completed.  As  the  primary  rights  and  obligations  of  the  MoU  have  been  fulfilled  including  the  transfer  all  its  media
business in airports (excluding digital TV screens in airports and TV-attached digital frames) and all billboard and LED media business outside of airports
(excluding  gas  station  media  network  and  digital  TV  screens  on  airplanes)  to  AM  Advertising,  and  transfer  of  the  trademark  to  AM  advertising,  and  the
Company  did  not  received  any  notice  of  cancellation  of  the  MoU  from  Beijing  Longde  Wenchuang  Investment  Fund  Management  Co.,  Ltd  and  Beijing
Cultural  Center  Construction  and  Development  Fund  (Limited  Partnership),  the  Company  believes  the  MoU  is  legally  valid.  The  Company  will  make
payment according to the MoU once the application for tax refund of AM Advertising finishes as agreed in the MoU. And once the tax refund finishes, the net
settlement amount may be reduced pursuant to the MoU.

In April 2015, we established AM Online, a variable interest entity of us, to operate the new Wi-Fi business.

33

 
 
 
 
 
 
 
 
 
 
In June 2015, Mr. Herman Man Guo submitted to the board of directors of the Company a preliminary nonbinding proposal letter (the “Proposal Letter”) to
acquire  the  Company  in  a  going  private  transaction  for  $3.00  in  cash  per  Share  (or  $6.00  in  cash  per  ADS)  other  than  any  ordinary  shares  or  ADSs
beneficially  held  by  Mr.  Guo,  his  affiliates  or  other  management  shareholders  who  may  choose  to  roll  over  their  Shares  in  connection  with  the  proposed
acquisition (the “Proposal”). The board of directors of the Company formed a special committee comprised of three independent and disinterested directors,
Messrs. Conor Chia-hung Yang, Shichong Shan and Songzuo Xiang, to negotiate the Proposal with the buyer group. On September 28, 2015, the Company
entered into a definitive agreement and plan of merger (the “Merger Agreement”) with AirMedia Holdings Ltd. (“Parent”) and AirMedia Merger Company
Limited, a wholly owned subsidiary of Parent, pursuant to which Parent will acquire the Company for $3.00 per Share (or $6.00 per ADS). Under the terms
of the Merger Agreement, either the Company or Parent could terminate the Merger Agreement if the merger contemplated by the Merger Agreement has not
been  completed  by  the  date  of  June  28,  2016.  In  2016  and  2017,  the  parties  entered  into  various  amendments  to  the  Merger  Agreement  to  extend  this
termination  date  and  amend  other  terms  of  the  Merger  Agreement.  The  Merger  Agreement  was  terminated  on  December  27,  2017  in  view  that  the  going
private transaction would not be completed by December 31, 2017.

In  January  2017,  we,  through  AM  Online,  established  Unicom  AirNet  (Beijing)  Network  Co.,  Ltd.,  or  Unicom  AirNet,  jointly  with  Unicom  Broadband
Online Co., Ltd., a wholly owned subsidiary of China Unicom, and Chengdu Haite Kairong Aeronautical Technology Co., Ltd., a wholly owned subsidiary of
a  listed  company  providing  aeronautical  technical  services.  Pursuant  to  a  capital  contribution  agreement  entered  into  by  the  relevant  parties,  AM  Online
invested an aggregate of RMB117.9 million in Unicom AirNet. AM Online currently holds 39% of equity interests in Unicom AirNet, and can designate three
directors to its seven-member board.  We and the other two shareholders of Unicom AirNet intend to build global network for aeronautical communication
and provide in-flight Internet and other value-added services through this newly established company. We believe that our respective expertise and advantages
in telecommunication and aeronautical technology can be fully utilized under this joint venture. 

In  November  2018,  Linghang  Shengshi,  Mr.  Guo  and  Mr.  Xu  entered  into  an  equity  transfer  agreement  with  Jiangsu  Hongzhou  Investment  Co.,  Ltd.,  an
independent third party to sell 20.32% equity interest of AM Advertising for an initial transfer price of RMB 580 million in cash. We have completed the
equity interest transfer and have received the installment payment of RMB 150 million for the year ended December 31, 2018 and RMB 50 million in January
2019 for the transfer pursuant to this equity transfer agreement. However, under this equity transfer agreement, the buyer may require sellers to repurchase the
20.32% equity interest upon the occurrence of certain events, we do not expect to repurchase the 20.32% equity interest as of the date of this annual report,
and we have accrued impairment of RMB 332 million for the 20.32% equity investment as of December 31, 2018. 

We are realigning our business by focusing our crucial resources on the further development of the in-flight connectivity business. In conjunction with this
realignment,  we  proposed  to  convene  an  extraordinary  general  meeting  on  May  20,  2019  to  change  our  name  from  "AirMedia  Group  Inc."  to  "AirNet
Technology Inc.".

Our  principal  executive  offices  are  located  at  15/F,  Sky  Plaza,  No.  46  Dongzhimenwai  Street,  Dongcheng  District,  Beijing  100027,  People’s  Republic  of
China. Our telephone number at this address is +86-10-8438-6868 and our fax number is +86-10-8460-8658. Our registered office in the Cayman Islands is at
the offices of Maples Corporate Services Limited, P.O. Box 309, Ugland House, Grand Cayman, KY1-1104, Cayman Islands.

See “Item 5. Operating and Financial Review and Prospects — B. Liquidity and Capital Resources — Capital Expenditures” for a discussion of our capital
expenditures.

B.

Business Overview

General

Driven by innovation, we gradually reinvented ourselves and shaped our core competence in providing in-flight solutions to connectivity, entertainment and
digital  multimedia  in  China.  Collaborating  with  our  partners,  we  provide  Chinese  airlines  with  seamless  and  immersive  Internet  connections  through  a
network of satellites and land-based beacons, furnish airline travelers with interactive entertainment and coverage of breaking news, and provide corporate
clients with advertisements tailored to the changing perceptions of the travelers.

Collaborating with China Unicom, we are licensed to provide in-flight connectivity over the Internet. Furthermore, backed by Honeywell’s next-generation
JetWave TM satellite communications hardware, we are able to provide airline travelers with a seamless and immersive Internet connection delivering the
same experience as it would’ve been otherwise on the ground. Moreover, our strategic partnership with China Eastern Airlines Media Co., Ltd. enables us to
deliver multimedia contents to travelers on airplanes operated by China Eastern Airlines through a mobile app.

34

 
 
 
 
 
 
 
 
 
 
 
 
 
 
In addition to our active endeavors in in-flight connectivity, we maintain a wide range of in-flight entertainment and advertising contents. As of March 31,
2019, we have access to in-flight entertainment and advertising contents including exclusive in-flight copyrights to over 80% of movies currently shown in
domestic theaters, more than 800 archived films, and thousands of hours of multimedia programs of entertainment nature covering a variety of topics such as
sports,  comedies,  local  attractions,  reality  shows,  commentaries,  documentaries.  As  of  March  31,  2019,  we  were  engaged  to  provide  copyrighted
entertainment contents to more than 30 airlines. Furthermore, we are engaged by hundreds of corporate clients to provide advertising contents across different
in-flight entertainment systems. Built upon our experiences, we are capable of developing entertainment contents independently and producing advertising
contents tailored to the needs of corporate clients.

Our entertainment contents usually show as individual programs lasting from approximately 45 minutes to 120 minutes of which approximately 3 minutes to
15 minutes are divided into slots sold to advertisers to show advertising contents of their choice. Our contents are usually showed on digital TV screens that
are highly visible to travelers or on mobile devices brought by travelers. We usually offer advertising time slots to the advertisers at a fix duration, time and
frequency of displaying advertisements. Payments of certain offering are subject to the receipt of monitoring reports verified by the advertisers. We generally
require a screening of the advertising contents at least 10 working days for digital media or 14 working days for conventional media before the contents are to
be aired. We reserve the right to refuse providing the service shall the advertising content fail to meet the requirements under PRC laws and regulations.

Our products and services combine in-flight connectivity and entertainment. To further grow our business, we are committed to take full advantage of our
partnership with China Unicom and Honeywell to improve travelers’ experience when they connect to the Internet en route of their travel. Meanwhile, we are
devoted to maintaining a versatile collection of entertainment contents covering a variety of aspects of lifestyles attracting traveling consumers. We are also
satisfying the advertising needs of corporate clients through our influence on travelling consumers.

Advertisers, Sales and Marketing

Our Advertisers

Our  advertisers  purchase  advertising  time  slots  and  locations  on  our  advertising  network  either  directly  from  us  or  through  advertising  agencies.  Many
advertisers negotiate the terms of the advertising purchase agreements directly with us, however we also rely on advertising agencies for a significant portion
of our sales.

We have a broad base of international and domestic advertisers in various industries. In each of 2016, 2017 and 2018, advisors from one industry, which is
automobiles, accounted for more than 10% of our total revenues from continuing operations. Nil, 1 and 2 of our customers accounted for more than 10% of
our total revenues for 2016, 2017 and 2018, respectively.

Sales and Marketing

We rely on our experienced sales team to assist advertisers in structuring advertising campaigns by analyzing advertisers’ target audiences and the form and
contents  of  the  advertisement  they  may  be  interested  in,  as  well  as  consumer  products  and  services.  We  conduct  market  research,  consumer  surveys,
demographic analysis and other advertising industry research for internal use to help our advertisers to create effective advertisements. We also use third-party
market research firms from time to time to obtain the relevant market study data, and at the same time hire such research firms to evaluate the effects of our
advertising, so as to evaluate the effectiveness of our network for our advertisers and to illustrate to our advertisers our ability to reach targeted demographic
groups effectively.

Our experienced advertising sales team is organized by region and city with a presence in many cities in China. We provide in-house education and training to
our sales force to ensure they provide our current and prospective advertisers with comprehensive information about our services, the advantages of using our
advertising network as a marketing channel, and relevant information regarding the advertising industry. Our performance-linked compensation structure and
career-oriented training are key drivers that motivate our sales employees.

35

 
 
 
 
 
 
 
 
 
 
 
 
 
 
We  actively  attend  various  public  relation  events  to  promote  our  brand  image  and  the  value  of  air  travel  digital  advertising.  We  market  our  advertising
services by displaying our name and logo on all of our digital TV screens on airplanes and gas station LED screens and by placing advertisements on third-
party media from time to time, including China Central Television. We also engage third-party advertising agencies to help source advertisers.

Pricing

The listing prices of our air travel advertising services depend on the passenger flow of each airline, the needs of each airline, the number of time slots and
display locations purchased, the cost of the relevant media assets, our costs for the relevant concession rights, and competition. Going forward, we intend to
review our listing prices periodically and make adjustments as necessary in light of market conditions.

Prices for advertisements on our network are fixed under our sales contracts with advertisers or advertising agencies, typically at a discount to our listing
prices.

Programming

Our  digital  TV  screens  on  network  airplanes  play  programs  ranging  from  45  minutes  to  120  minutes  once  per  flight.  We  compile  each  cycle  from
advertisements of 5-, 15- or 30-seconds in length provided by advertisers to us and from non-advertising content generated by our VIEs in China or provided
by third-party content providers. We generally create a programming list on a weekly and monthly basis for programs played on airplanes, respectively. We
create  this  list  by  first  fixing  the  schedule  for  advertising  content  according  to  the  respective  sales  contracts  with  our  advertisers  to  guarantee  the  agreed
duration, time and frequency of advertisements for each advertiser, then adding the non-advertising content to achieve an optimal blend of advertising and
non-advertising content.

Substantially all of the advertisements on our network are provided by our advertisers. All of the advertising content displayed on our advertising network is
reviewed by us to ensure compliance with PRC laws and regulations. See “—Regulation—Regulation of Advertising Services—Advertising Content.” We
update advertising content for our programs played on digital TV screens on airplanes on a monthly basis. A majority of the non-advertising content played
on our network is provided by third-party content providers such as Dragon TV, the Travel Channel and various satellite and cable television stations and
television production companies. In January 2014, we entered into a strategic partnership with China Radio International Oriental Network (Beijing) Co., Ltd,
which  manages  the  internet  TV  business  of  China  International  Broadcasting  Network,  to  operate  the  CIBN-AirMedia  channel  to  broadcast  network  TV
programs to air travelers in China.

Our programming team edits, compiles and records into digital format for all of our network programs according to the programming list. Each programming
list  and  pre-recorded  program  is  carefully  reviewed  to  ensure  the  accuracy  of  the  order,  duration  and  frequency  as  well  as  the  appropriateness  of  the
programming content.

Display Equipment Supplies and Maintenance 

The  primary  hardware  required  for  the  operation  of  our  air  travel  advertising  network  are  the  digital  TV  screens  that  we  use  in  our  media  network.  The
majority  of  our  digital TV  screens  consist  of  plasma  display  panels  and  LCDs.  Maintaining  a  steady  supply  of  our  display  equipment  is  important  to  our
operations and the growth of our network. Our TV screen suppliers typically provide us with one-year warranties. Our service team cleans, maintains and
monitors our digital TV screens on airplanes regularly.

36

 
 
 
 
 
 
 
 
 
 
 
 
 
 
For our traditional media platforms in airports, the primary hardware was already established when we purchased the traditional media from airports, and we
do not incur significant maintenance costs in relation to these platforms.

For our gas stations media network, the primary hardware consists of basic display equipment that we install and maintain. In 2016 and 2017, 45 and 66
suppliers,  respectively,  together  supplied  a  majority  of  our  gas  station  display  equipment.  In  early  2018,  the  management  assessed  the  operational
underperformance  of  our  Wi-Fi  services  on  trains,  long-haul  buses  and  gas  station  media  service,  which  indicated  that  the  underperformance  could  be
ascribed  to  i)  the  wide  spread  of  4G  technology  and  affordable  data  plans;  and  ii)  the  depleting  marketing  budget  of  some  of  our  advertisers.  In  order  to
prevent further losses while seizing the opportunities from other components such as air travel media service, we gradually ceased our operations of Wi-Fi
service on long-haul buses and our gas station media services, and scaled down operations in providing Wi-Fi services on trains.

Customer Service

Our customer service team is responsible for contacting third-party research firms to compile evaluation reports based on selective sampling of the status of
advertising on our network and providing advertisers with monthly monitoring reports once the relevant advertising campaign is launched on our network. At
the same time, we also provide our advertisers with monthly reports prepared by third parties that verify the proper functioning of our displays and the proper
dissemination of the advertisement when required by our advertisers; such reports are done through online survey to analyze the effectiveness of and public
reaction to the advertisements. In addition, our network airlines, as well as trains are also actively involved in the monitoring process.

Competition

We compete primarily with several different groups of competitors in the air travel advertising market:

·

·

in-house advertising companies of airlines that may operate their own advertising networks; and 

traditional advertising media, such as newspapers, television, magazines and radio.  

We  compete  for  advertisers  primarily  on  the  basis  of  location,  price,  program  quality,  range  of  services  offered  and  brand  recognition.  See  “Item  3.  Key
Information—D. Risk Factors — Risks Related to Our Business — We face significant competition in the PRC advertising industry, and if we do not compete
successfully against new and existing competitors, we may lose our market share, and our profits may be reduced.”

Intellectual Property

To protect our brand and other intellectual property, we rely on a combination of trademark and trade secret laws as well as confidentiality agreements with
our employees, sales agents, contractors and others. As of March 31, 2019, we have registered 23 major trademarks and one patent in China, including “(cid:0)(cid:0)”,
“(cid:0)(cid:0)” and “(cid:0)(cid:0)”. We cannot be certain that our efforts to protect our intellectual property rights will be adequate or that third parties will not infringe or
misappropriate these rights.

Regulation 

We operate our business in China under a legal regime consisting of the State Council, which is the highest authority of the executive branch of the National
People’s Congress, and several ministries and agencies under its authority including the SAMR.

China’s Advertising Law was promulgated in 1994, and was revised in 2015 and further revised in 2018. In addition, the State Council, SAIC (which has
merged into the SAMR in March 2018) and other ministries and agencies have issued regulations that regulate our business, all of which are discussed below.

37

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Limitations on Foreign Ownership in the Advertising Industry

The  Foreign  Investment  Industrial  Guidance  Catalogue,  and  relevant  provisions  provide  that  foreign  investment  projects  are  divided  into  four  categories:
encouraged, permitted, restricted and prohibited. The foreign investment projects that are encouraged, restricted and prohibited shall be listed in the Foreign
Investment Industrial Guidance Catalogue. The foreign investment projects that do not fall into the categories of encouraged, restricted or prohibited projects
are considered permitted foreign investment projects and are not listed in the Foreign Investment Industrial Guidance Catalogue. Applicable regulations and
approval requirements vary based on the different categories. Investments in the PRC by foreign investors through wholly foreign-owned enterprises must be
in  compliance  with  the  applicable  regulations,  and  such  foreign  investors  must  obtain  governmental  approvals  as  required  by  these  regulations.  Since  the
advertising industry is not listed in the Foreign Investment Industrial Guidance Catalogue, it falls into the permitted foreign investment category.

Since  December  10,  2005,  foreign  investors  have  been  permitted  to  directly  own  a  100%  interest  in  advertising  companies  in  China.  PRC  laws  and
regulations do not permit the transfer of any approvals, licenses or permits, including business licenses containing a scope of business that permits engaging
in the advertising industry. In the event we are permitted to acquire the equity interests of our VIEs under the rules allowing for complete foreign ownership,
our VIEs would continue to hold the required advertising licenses consistent with current regulatory requirements.

Currently,  our  advertising  business  is  mainly  conducted  through  contractual  arrangements  with  our  consolidated  VIEs  in  China,  including  AM  Online,
Linghang Shengshi, Jiaming Advertising, Guangzhou Meizheng and Beijing Yuehang.

Our VIEs are the major companies through which we provide advertising services in China. Our subsidiary, Chuangyi Technology, has entered into a series of
contractual arrangements with our PRC operating affiliates and their respective subsidiaries and shareholders under which:

·

·

·

we are able to exert effective control over our PRC operating affiliates and their respective subsidiaries;  

a substantial portion of the economic benefits of our PRC operating affiliates and their respective subsidiaries could be transferred to us; and 

we have an exclusive option to purchase all of the equity interests in our PRC operating affiliates (except for those owned by Yi Zhang) in each case
when and to the extent permitted by PRC law.  

See “Item 4. Information on the Company—C. Organizational Structure” and “Item 7. Major Shareholders and Related Party Transactions—B. Related Party
Transactions—Contractual Arrangements.”

In the opinion of Commerce & Finance Law Offices, our PRC legal counsel: except as described in this annual report, the respective ownership structures of
Chuangyi  Technology  and  our  consolidated  VIEs  do  not  violate  existing  PRC  laws  and  regulations,  and  the  contractual  arrangements  among  Chuangyi
Technology and our consolidated VIEs, in each case governed by PRC law, are valid, binding and enforceable.

We have been advised by our PRC legal counsel, however, that there are some uncertainties regarding the interpretation and application of current and future
PRC laws and regulations. Accordingly, there can be no assurance that the PRC regulatory authorities, in particular the SAMR (which regulates advertising
companies), will not in the future take a view that is contrary to the opinion of our PRC legal counsel. We have been further advised by our PRC counsel that
if  the  PRC  government  determines  that  the  agreements  establishing  the  structure  for  operating  our  PRC  advertising  business  do  not  comply  with  PRC
government restrictions on foreign investment in the advertising industry, we could be subject to certain penalties. See “Item 3. Key Information—D. Risk
Factors—Risks Related to Our Corporate Structure—If the PRC government finds that the agreements that establish the structure for operating our China
business do not comply with PRC governmental restrictions on foreign investment in the advertising industry and in the operating of non-advertising content,
our business could be materially and adversely affected.”

Regulation on Foreign Investment

On March 15, 2019, the Foreign Investment Law was enacted by the National People’s Congress and it will become effective on January 1, 2020. Upon its
enactment, it will replace the trio of existing laws regulating foreign investment in China, namely, the Sino-foreign Equity Joint Venture Enterprise Law, the
Sino-foreign  Cooperative  Joint  Venture  Enterprise  Law  and  the  Wholly  Foreign-invested  Enterprise  Law,  together  with  their  implementation  rules  and
ancillary regulations. The Foreign Investment Law embodies an expected PRC regulatory trend to rationalize its foreign investment regulatory regime in line
with prevailing international practice and the legislative efforts to unify the corporate legal requirements for both foreign and domestic investments.

Unlike its first draft which was published in 2015, the approved Foreign Investment Law does not explicitly define the contractual arrangements with VIEs as
a  form  of  foreign  investment.  It  contains  an  ambiguous  clause  that  covers  other  form  stipulated  in  laws,  administrative  regulations  or  other  methods
prescribed by the State Council within its definition of foreign investment. Therefore, uncertainties still exist about whether the contractual arrangements with
VIEs will be deemed to violate the market access requirements for foreign investment under the PRC laws.

Moreover, the Foreign Investment Law establishes a foreign investment information reporting system. Foreign investors or foreign-funded enterprises shall
submit the investment information to competent authorities through the enterprise registration system and the enterprise credit information publicity system.
The contents and scope of foreign investment information to be reported shall be determined by the principle of necessity. Where foreign-investors or foreign-
invested enterprises are found to be non-compliant with these information reporting obligations, competent commerce authority shall ask for corrections with
a specified period; if such corrections are not made in time, a penalty of not less than RMB100,000 yet not more than RMB500,000 shall be imposed. Other
than reporting foreign investment information, the Foreign Investment Law also establishes a security examination mechanism for foreign investment and
conducts security review of foreign investment that affects or may affect national security. The decision made upon the security examination in accordance
with the law shall be final.

38

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Regulation of Advertising Services

Business License for Advertising Companies

Under applicable regulations governing advertising businesses in China, companies that engage in advertising activities must obtain from the SAMR or its
local  branches  a  business  license  which  specifically  includes  within  its  scope  the  operation  of  an  advertising  business.  Companies  conducting  advertising
activities without such a license may be subject to penalties, including fines, confiscation of advertising income and orders to cease advertising operations.
The business license of an advertising company is valid for the duration of its existence, unless the license is suspended or revoked due to a violation of any
relevant law or regulation. We do not expect to encounter any difficulties in maintaining our business licenses. Each of our VIEs has obtained such a business
license from the local branches of the SAMR as required by existing PRC regulations.

Each of Beijing Yuehang Digital and AM Online has valid business license as of the date of this annual report. The business scope of these two entities as set
forth in their business licenses include the development of electronic, computer and media-related technologies and products and do not include advertising,
due to certain restrictions on foreign ownership of advertising enterprises under PRC law.

Advertising Content

PRC advertising laws and regulations set forth certain content requirements for advertisements in China, which include prohibitions on, among other things,
misleading content, superlative wording, socially destabilizing content or content involving obscenities, superstition, violence, discrimination or infringement
of the public interest. Advertisements for anesthetic, psychotropic, toxic or radioactive drugs are prohibited. The dissemination of tobacco advertisements via
media  is  also  prohibited  as  well  as  the  display  of  tobacco  advertisements  in  public  areas.  There  are  also  specific  restrictions  and  requirements  regarding
advertisements  that  relate  to  matters  such  as  patented  products  or  processes,  pharmaceuticals,  medical  instruments,  agrochemicals,  foodstuff,  alcohol  and
cosmetics. In addition, all advertisements relating to pharmaceuticals, medical instruments, agrochemicals and veterinary pharmaceuticals advertised through
any media, together with any other advertisements subject to censorship by administrative authorities under relevant laws and administrative regulations, must
be submitted to the relevant administrative authorities for content approval prior to dissemination. We do not believe that advertisements containing content
subject to restriction or censorship comprise a material portion of the advertisements displayed on our network.

Advertisers,  advertising  operators  and  advertising  distributors  are  required  by  PRC  advertising  laws  and  regulations  to  ensure  that  the  content  of  the
advertisements  they  prepare  or  distribute  are  true  and  in  full  compliance  with  applicable  law.  In  providing  advertising  services,  advertising  operators  and
advertising  distributors  must  review  the  prescribed  supporting  documents  provided  by  advertisers  for  advertisements  and  verify  that  the  content  of  the
advertisements  comply  with  applicable  PRC  laws  and  regulations.  In  addition,  prior  to  distributing  advertisements  for  certain  items  which  are  subject  to
government  censorship  and  approval,  advertising  distributors  are  obligated  to  ensure  that  such  censorship  has  been  performed  and  approval  has  been
obtained.  Violation  of  these  regulations  may  result  in  penalties,  including  fines,  confiscation  of  advertising  income,  orders  to  cease  dissemination  of  the
advertisements and orders to publish an advertisement correcting the misleading information. In circumstances involving serious violations, the SAMR or its
local branches may revoke violators’ licenses or permits for advertising business operations. Furthermore, advertisers, advertising operators or advertising
distributors may be subject to civil liability if they infringe the legal rights and interests of third parties in the course of their advertising business.

Outdoor Advertising

The PRC Advertising Law stipulates that the exhibition and display of outdoor advertisements must not:

·

·

·

utilize traffic safety facilities and traffic signs;  

impede the use of public facilities, traffic safety facilities and traffic signs;  

obstruct commercial and public activities or create an unpleasant sight in urban areas;  

39

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
·

·

be placed in restrictive areas near government offices, cultural landmarks or historical or scenic sites; or 

be placed in areas prohibited by the local governments at or above county level from having outdoor advertisements.  

In addition, according to a relevant SARFT circular, displaying audio-video programs such as television news, films and television shows, sports, technology
and entertainment through public audio-video systems located in automobiles, buildings, airports, bus or train stations, shops, banks and hospitals and other
outdoor public systems must be approved by the SARFT. The relevant authority in China has not promulgated any implementation rules on the procedure of
applying for the requisite approval pursuant to the SARFT circular.

Regulations on Foreign Exchange

The principal regulation governing foreign currency exchange in China is the Foreign Currency Administration Rules, which became effective in 1996, and
was further amended in 2008. Under these Rules, RMB is freely convertible for current account items, such as trade and service-related foreign exchange
transactions, but not for capital account items, such as direct investment, loan or investment in securities outside China unless the prior approval of, and/or
registration with, SAFE or its local counterparts (as the case may be) is obtained.

On  March  30,  2015,  SAFE  promulgated  the  Circular  on  Reforming  the  Management  Approach  Regarding  the  Foreign  Exchange  Capital  Settlement  of
Foreign-invested Enterprises, or SAFE Circular 19, which will took effect on June 1, 2015. On June 9, 2016, the SAFE promulgated the Circular of the State
Administration of Foreign Exchange on Reforming and Regulating Policies on the Control over Foreign Exchange Settlement of Capital Accounts, or SAFE
Circular 16, which revised some provisions of SAFE Circular 19. SAFE Circular 19 and SAFE Circular 16 allows foreign-invested enterprises to settle 100%
of their foreign exchange capitals on a discretionary basis and allows ordinary foreign-invested enterprises to make domestic equity investments by capital
transfer in the original currencies, or with the amount obtained from foreign exchange settlement, subject to complying with certain requirements. According
to SAFE Circular 19 and SAFE Circular 16, the RMB funds obtained by foreign-invested enterprises from the discretionary settlement of foreign exchange
capitals shall be managed under the accounts pending for foreign exchange settlement payment, and foreign-invested enterprise shall not use its capital and
the RMB funds obtained from foreign exchange settlement for the purposes within the following negative list: for expenditure beyond its business scope or
expenditure prohibited by laws and regulations, for investments in securities or other investments than banks’ principal-secured products,, for the granting of
loans to non-affiliated enterprises, except where it is expressly permitted in the business license, or for construction or expenses related to the purchase of real
estate  not  for  self-use,  unless  it  is  a  foreign-invested  real  estate  enterprise.  Moreover,  on  January  26,  2017,  SAFE  promulgated  Circular  of  the  State
Administration of Foreign Exchange on Further Advancing the Reform of Foreign Exchange Administration and Improving Examination of Authenticity and
Compliance,  or  Circular  3. The  Circular  3  states  several  control  measures  with  respect  to  the  outbound  remittance  of  any  profit  from  domestic  entities  to
offshore entities, including (i) under the principle of genuine transaction, banks should review board resolutions, the original version of tax filing records and
audited  financial  statements  before  wiring  the  foreign  exchange  profit  distribution  of  a  foreign-invested  enterprise  exceeding  $50,000;  and  (ii)  domestic
entities should hold income to make up previous years’ losses before remitting the profits to offshore entities. Meanwhile, verification on the genuineness and
compliance of foreign direct investments in domestic entities has also been tightened in accordance with Circular 3,

Pursuant to SAFE Circular 19, SAFE Circular 16 and SAFE Circular 3, foreign invested enterprises in China may convert part or all of the amount of the
foreign  currency  in  its  capital  account,  special  account  for  foreign  debt  or  special  account  for  overseas  listing  into  RMB  at  any  time  after  going  through
capitals  review  process  with  bank  and  supplement  necessary  supporting  documents  upon  bank’s  request  for  verification  on  genuineness  and  compliance.
Nevertheless, it is still not clear whether foreign-invested enterprises like our PRC subsidiaries are allowed to extend intercompany loans to our VIEs.

Regulations on Dividend Distribution

Under applicable PRC regulations, wholly foreign-owned companies in the PRC may pay dividends only out of their accumulated profits as determined in
accordance with PRC accounting standards and regulations. Additionally, these wholly foreign-owned companies are required to set aside at least 10% of
their  respective  accumulated  profits  each  year,  if  any,  to  fund  certain  reserve  funds  until  their  cumulative  total  reserve  funds  have  reached  50%  of  the
companies’ registered capitals. At the discretion of these wholly foreign-owned companies, they may allocate a portion of their after-tax profits based on PRC
accounting standards to staff welfare and bonus funds. These reserve funds and staff welfare and bonus funds are not distributable as cash dividends except in
the event of liquidation and cannot be used for working capital purposes.

40

 
 
 
 
 
 
 
 
 
 
 
 
 
In addition, under the EIT Law and its implementing rules, dividends generated after January 1, 2008 and payable by a FIE in China to its foreign investors
who are non-resident enterprises will be subject to a 10% withholding tax unless any such foreign investor’s jurisdiction of incorporation has a tax treaty with
China that provides for a different withholding arrangement. BVI, where Broad Cosmos, our wholly owned subsidiary, is incorporated, does not have such a
tax treaty with China. AN China, the 100% shareholder of Chuangyi Technology, Shenzhen Yuehang and Xi’an Shengshi, is incorporated in Hong Kong.
According to the Mainland and Hong Kong Special Administrative Region Arrangement on Avoiding Double Taxation or Evasion of Taxation on Income
agreed between China and Hong Kong in August 2006, dividends paid by a foreign-invested enterprise in China to its direct holding company in Hong Kong
will  be  subject  to  withholding  tax  at  a  rate  of  5%  (if  the  foreign  investor  owns  directly  at  least  25%  of  the  shares  of  the  foreign-invested  enterprise).  In
October  2015,  the  State  Administration  of  Taxation  released  the  Administrative  Measures  for  Non-Residents  Enjoying  Tax  Treaty  Benefits  (Trial
Implementation), which took effect on November 1, 2015. Under these measures, our Hong Kong subsidiary needs to obtain approval from the competent
local branch of the State Administration of Taxation in order to enjoy the preferential withholding tax rate of 5% in accordance with the Double Taxation
Arrangement. In February 2009, the State Administration of Taxation issued Notice No. 81. According to Notice No. 81, in order to enjoy the preferential
treatment on dividend withholding tax rates, an enterprise must be the “beneficial owner” of the relevant dividend income, and no enterprise is entitled to
enjoy preferential treatment pursuant to any tax treaties if such enterprise qualifies for such preferential tax rates through any transaction or arrangement, the
major purpose of which is to obtain such preferential tax treatment. The tax authority in charge has the right to make adjustments to the applicable tax rates, if
it determines that any taxpayer has enjoyed preferential treatment under tax treaties as a result of such transaction or arrangement. In October 2009, the State
Administration of Taxation issued another notice on this matter, or Notice No. 601, to provide guidance on the criteria to determine whether an enterprise
qualifies as the “beneficial owner” of the PRC sourced income for the purpose of obtaining preferential treatment under tax treaties. Pursuant to Notice No.
601, the PRC tax authorities will review and grant tax preferential treatment on a case-by-case basis and adopt the “substance over form” principle in the
review. Notice 601 specifies that a beneficial owner should generally carry out substantial business activities and own and have control over the income, the
assets  or  other  rights  generating  the  income.  Therefore,  an  agent  or  a  conduit  company  will  not  be  regarded  as  a  beneficial  owner  of  such  income.  On
February 3, 2018, SAT issued Announcement of the State Administration of Taxation on Issues concerning “Beneficial Owners” in Tax Treaties, or Circular
9, which became effective on April 1, 2018 and superseded Notice No. 601. In comparison with Notice No. 601, Circular 9 enlarging and further explaining
the  scope  of  beneficial  owner,  supplementing  the  applicants  deemed  as  beneficial  owners  who  obtain  proceeds  from  China  as  direct  or  indirect  100%
shareholder, increasing the certainty of identifying beneficial owner. Since the two notices were issued, it has remained unclear how the PRC tax authorities
will implement them in practice and to what extent they will affect the dividend withholding tax rates for dividends distributed by our subsidiaries in China to
our  Hong  Kong  subsidiary.  If  the  relevant  tax  authority  determines  that  our  Hong  Kong  subsidiary  is  a  conduit  company  and  does  not  qualify  as  the
“beneficial owner” of the dividend income it receives from our PRC subsidiaries, the higher 10% withholding tax rate may apply to such dividends.

The EIT Law provides, however, that dividends distributed between qualified resident enterprises are exempted from the withholding tax. According to the
Implementation Regulations of the EIT Law, the qualified dividend and profit distribution from equity investment between resident enterprises shall refer to
investment income derived by a resident enterprise from its direct investment in other resident enterprises, except the investment income from circulating
stocks  issued  publicly  by  resident  enterprises  and  traded  on  stock  exchanges  where  the  holding  period  is  less  than  12  months.  As  the  term  “resident
enterprises” needs further clarification and interpretation, we cannot assure you that the dividends distributed by Chuangyi Technology, Shenzhen Yuehang
and Xi’an Shengshi to their direct shareholders would be regarded as dividends distributed between qualified resident enterprises and be exempted from the
withholding tax.

41

 
 
 
 
 
 
Under the EIT Law and related regulations, an enterprise established outside of the PRC with “de facto management bodies” within the PRC is considered a
PRC resident enterprise and is subject to the EIT at the rate of 25% on its worldwide income. The related regulations define the term “de facto management
bodies”  as  “establishments  that  carry  out  substantial  and  overall  management  and  control  over  the  manufacturing  and  business  operations,  personnel,
accounting,  properties,  etc.  of  an  enterprise.”  The  SAT  issued  the  Notice  Regarding  the  Determination  of  Chinese-Controlled  Overseas  Incorporated
Enterprises as PRC Tax Resident Enterprises on the Basis of De Facto Management Bodies, or SAT Circular 82, on April 22, 2009, which was amended in
2013  and  2017  respectively.  SAT  Circular  82  provides  certain  specific  criteria  for  determining  whether  the  “de  facto  management  body”  of  a  Chinese-
controlled  overseas-incorporated  enterprise  is  located  in  China.  In  addition,  the  SAT  issued  a  bulletin  on  July  27,  2011  to  provide  more  guidance  on  the
implementation  of  SAT  Circular  82  with  an  effective  date  to  be  September  1,  2011.  The  bulletin  provided  clarification  in  the  areas  of  resident  status
determination,  post-determination  administration,  as  well  as  competent  tax  authorities.  It  also  specifies  that  when  provided  with  a  copy  of  a  Chinese  tax
resident determination certificate from a resident Chinese controlled offshore incorporated enterprise, the payer should not withhold 10% income tax when
paying the Chinese-sourced dividends, interest, royalties, etc. to the Chinese controlled offshore incorporated enterprise. Although both SAT Circular 82 and
the  bulletin  only  apply  to  offshore  enterprises  controlled  by  PRC  enterprises,  not  to  those  that,  like  our  company,  are  controlled  by  PRC  individuals,  the
determination criteria set forth in SAT Circular 82 and administration clarification made in the bulletin may reflect the SAT’s general position on how the “de
facto management body” test should be applied in determining the tax residency status of offshore enterprises and the administration measures that should be
implemented, regardless of whether they are controlled by PRC enterprises or PRC individuals.

Moreover, under the EIT Law, if we are classified as a PRC resident enterprise and such income is deemed to be sourced from within the PRC, foreign ADS
holders may be subject to a 10% withholding tax upon dividends payable by us and gains realized on the sale or other disposition of ADSs or ordinary shares.

See “Item 3. Key Information — D. Risk Factors — Risks Related to our Business — Dividends payable to us by our wholly-owned operating subsidiaries
may be subject to PRC withholding taxes, or we may be subject to PRC taxation on our worldwide income, and dividends distributed to our investors may be
subject to more PRC withholding taxes under the PRC tax law.”

SAFE Regulations on Offshore Investment by PRC Residents and Employee Stock Options

In October 2005, the SAFE issued the Notice on Issues Relating to the Administration of Foreign Exchange in Fund-raising and Return Investment Activities
of Domestic Residents Conducted via Offshore Special Purpose Companies, or SAFE Circular 7, which became effective as of November 1, 2005. SAFE
Circular 7 suspends the implementation of two prior regulations promulgated in January and April of 2005 by the SAFE. On July 4, 2014, SAFE issued the
SAFE’s Notice on Relevant Issues Concerning Foreign Exchange Administration for PRC Residents to Engage in Outbound Investment and Financing and
Inbound Investment via Special Purpose Vehicles, or SAFE Circular 37, which has superseded SAFE Circular 75. Under SAFE Circular 75, SAFE Circular
37 and other relevant foreign exchange regulations, PRC residents who make, or have previously made, prior to the implementation of these foreign exchange
regulations, direct or indirect investments in offshore companies will be required to register those investments. In addition, any PRC resident who is a direct
or indirect shareholder of an offshore company is also required to file or update the registration with the local branch of SAFE, with respect to that offshore
company for any material change involving its round-trip investment, capital variation, such as an increase or decrease in capital, transfer or swap of shares,
merger, division, long-term equity or debt investment or the creation of any security interest. If any PRC shareholder fails to make the required registration or
update the previously filed registration, the PRC subsidiary of that offshore parent company may be prohibited from distributing their profits and the proceeds
from any reduction in capital, share transfer or liquidation to their offshore parent company, and the offshore parent company may also be prohibited from
injecting additional capital into its PRC subsidiary. Moreover, failure to comply with the various foreign exchange registration requirements described above
could result in liability under PRC laws for evasion of applicable foreign exchange restrictions.

42

 
 
 
 
 
 
 
 
 
In  December  2006,  the  People’s  Bank  of  China  promulgated  the  Administrative  Measures  of  Foreign  Exchange  Matters  for  Individuals,  or  the  PBOC
Regulation,  setting  forth  the  respective  requirements  for  foreign  exchange  transactions  by  PRC  individuals  under  either  the  current  account  or  the  capital
account. In January 2007, the SAFE issued implementing rules for the PBOC Regulation, which, among other things, specified approval requirements for
certain capital account transactions such as a PRC citizen’s participation in the employee stock ownership plans or stock option plans of an overseas publicly-
listed company. On February 15, 2012, the SAFE promulgated the Circular on Relevant Issues Concerning Foreign Exchange Administration for Domestic
Individuals Participating in an Employee Share Incentive Plan of an Overseas-Listed Company (which replaced the old Circular 78, “Application Procedure
of Foreign Exchange Administration for Domestic Individuals Participating in an Employee Stock Holding Plan or Stock Option Plan of an Overseas-Listed
Company” promulgated on March 28, 2007), or the New Share Incentive Rule. Under the New Share Incentive Rule, PRC citizens who participate in a share
incentive plan of an overseas publicly listed company are required to register with SAFE and complete certain other procedures. All such participants need to
retain  a  PRC  agent  through  a  PRC  subsidiary  to  register  with  SAFE  and  handle  foreign  exchange  matters  such  as  opening  accounts  and  transferring  and
settlement  of  the  relevant  proceeds.  The  New  Share  Incentive  Rule  further  requires  that  an  offshore  agent  should  also  be  designated  to  handle  matters  in
connection with the exercise or sale of share options and proceeds transferring for the share incentive plan participants.

We  and  our  PRC  employees  who  have  been  granted  stock  options  are  subject  to  the  New  Share  Incentive  Rule.  We  are  in  the  process  of  completing  the
required  registration  and  the  procedures  for  the  New  Share  Incentive  Rule  under  PRC  laws,  but  the  application  documents  are  subject  to  the  review  and
approval  of  the  SAFE,  and  we  can  make  no  assurance  as  to  when  the  registration  and  procedures  will  be  completed.  If  we  or  our  PRC  employees  fail  to
comply with the New Share Incentive Rule, we and/or our PRC employees may face sanctions imposed by the foreign exchange authority or any other PRC
government authorities.

In addition, the State Administration of Taxation has issued a few circulars concerning employee stock options. Under these circulars, our employees working
in  China  who  exercise  stock  options  will  be  subject  to  PRC  individual  income  tax.  Our  PRC  subsidiaries  have  obligations  to  file  documents  related  to
employee  stock  options  with  relevant  tax  authorities  and  withhold  individual  income  taxes  of  those  employees  who  exercise  their  stock  options.  If  our
employees fail to pay and we fail to withhold their income taxes, we may face sanctions imposed by tax authorities or any other PRC government authorities.

Seasonality

Our operating results and operating cash flows historically have been subject to seasonal variations. This pattern may change, however, as a result of new
market opportunities or new product introductions.

43

 
 
 
 
 
 
 
 
 
C.       Organizational Structure

The following diagram illustrates our principal subsidiaries, VIEs and VIEs’ subsidiaries as of March 31, 2019:

Notes:
(1) Several of our principal subsidiaries, VIEs and VIEs’ subsidiaries as of March 31, 2019 have changed their names compared to as of December 31, 2017.

Following is for the details.
Air Net International Limited (Formerly AirMedia International Limited (“Air Net International”)
Air Net (China) Limited (Formerly AirMedia (China) Limited) (“AN China”)
Yuehang Chuangyi Technology (Beijing) Co., Ltd. (Formerly AirMedia Technology (Beijing) Co., Ltd.) Shenzhen Yuehang Information Technology Co.,
Ltd. (Formerly Shenzhen AirMedia Information Technology Co., Ltd.)
Xi’an Shengshi Dinghong Information Technology Co., Ltd. (Formerly Xi’an AirMedia Chuangyi Technology Co., Ltd.)
Beijing Linghang Shengshi Advertising Co., Ltd. (Formerly Beijing AirMedia Shengshi Advertising Co., Ltd.)
Beijing Wangfan Jiaming Advertising Co.,Ltd. (Formerly Beijing AirMedia Jiaming Advertising Co., Ltd.)
AirMedia Online Network Technology Group Co., Ltd. (Formerly AirMedia Online Network Technology Co., Ltd.)
Beijing Airnet Pictures Co., Ltd. (Formerly Beijing AirMedia Film & TV Culture Co., Ltd.)
Beijing Zhihe Xianglong Advertising Co., Ltd. (Formerly Flying Dragon Media Advertising Co., Ltd.)
Wenzhou Yuehang Advertising Co., Ltd. (Wenzhou AirMedia Advertising Co., Ltd.)
Beijing Yuehang Tianyi Electronic Information Technology Co., Ltd.(Formerly Beijing AirMedia Tianyi Information Technology Co., Ltd.)
Wangfan Linghang Mobile Network Technology Co., Ltd. (Formerly AirMedia Mobile Network Technology Co., Ltd.)
Beijing Wangfan Jiaming Pictures Co., Ltd. (Formerly Beijing AirMedia Jiaming Film & TV Culture Co., Ltd.)

(2) AirMedia  Online  Network  Group  Technology  Co.,  Ltd.  is  77.2%,  14.5%,  4.8%  and  3.5%  owned  by  Herman  Man  Guo,  Qing  Xu,  Tao  Hong  and  Yi
Zhang,  respectively.  Yi  Zhang  divested  all  the  3.5%  equity  interest  in  AirMedia  Online  Network  Group  Technology  Co.,  Ltd  in  2018.  However,  the
registration of such alternation is in progress in the local administration for industry and commerce as of the date of this annual report.

(3) On  December  15,  2016,  AM  Online  and  an  individual  signed  concurrently  an  equity  transfer  agreement  and  an  entrusted  equity  holding  agreement,
pursuant  to  which  AM  Online  transferred  100%  equity  interests  in  Beijing  Yuehang  Digital  Media  Advertising  Co.,  Ltd.,  or  Beijing  Yuehang,  to  the
individual  and  entrusted  the  individual  to  act  as  the  nominee  shareholder  of  the  foregoing  equity  interests.  The  entrusted  equity  holding  agreement
terminates upon the earlier of (i) two years from the date of the entrusted equity holding agreement or (ii) the transfer of all entrusted equity by AM
Online to AM Online itself or a third party designated by AM Online. AM Online as the actual investor in Beijing Yuehang continues to hold actual
shareholder rights and receive benefits from the investment in Beijing Yuehang.

44

 
 
 
 
 
 
 
 
 
 
 
(4) Beijing  AirMedia  Jiaming  Advertising  Co.,  Ltd.  is  1.0%,  0.2%  and  98.8%  owned  by  Herman  Man  Guo,  Qing  Xu  and  Beijing  Linghang  Shengshi

Advertising Co., Ltd., respectively.

(5) Beijing Linghang Shengshi Advertising Co., Ltd. is 83.6%, 12.5%, 3.8% and 0.1% owned by Herman Man Guo, Qing Xu , Yi Zhang and Xiao Ya Zhang,
respectively. Yi Zhang Yi divested all the 3.8% equity interest in Beijing Linghang Shengshi Advertising Co., Ltd in 2018. However, the registration of
such alternation is in progress in the local administration for industry and commerce as of the date of this annual report.

Substantially  all  of  our  operations  are  conducted  through  contractual  arrangements  with  our  consolidated  VIEs  in  China,  Linghang  Shengshi,  Jiaming
Advertising,  Beijing Yuehang,  Guangzhou  Meizheng  and  AM  Online.  We  do  not  have  any  equity  interests  in  our  VIEs,  but  instead  enjoy  the  economic
benefits derived from them through a series of contractual arrangements. See “Item 7. Major Shareholders and Related Party Transactions—B. Related Party
Transactions—Contractual Arrangements” for a description of these arrangements.

D.

Property, Plants and Equipment

Our headquarters are located in Beijing, China, where we lease approximately 5,026 square meters of office space. Our branch offices lease approximately
3,671 square meters of office space in seven other locations.

In  addition,  we  own  approximately  2,109  square  meters  of  office  space  in  China.  In  September  2014  and  April  2015,  we  entered  into  the  agreements  to
purchase an office space of approximately 2,109 square meters in Beijing for a total consideration of RMB65 million ($9.4 million).

ITEM 4A.

UNRESOLVED STAFF COMMENTS

None.

ITEM 5.

OPERATING AND FINANCIAL REVIEW AND PROSPECTS 

You  should  read  the  following  discussion  and  analysis  of  our  financial  condition  and  results  of  operations  in  conjunction  with  our  consolidated  financial
statements and the related notes included elsewhere in this annual report on Form 20-F. This discussion may contain forward-looking statements. Our actual
results may differ materially from those anticipated in these forward-looking statements because of various factors, including those set forth under “Item 3.
Key Information—D. Risk Factors” or in other parts of this annual report on Form 20-F. See “Forward-looking Information.”

A.

Operating Results

Important Factors Affecting the Results of Operations of Our Air Travel Advertising, Gas Station Media Business and Trains, Buses and Airline Wi-
Fi Business  

In early 2018, the management assessed the operational underperformance of our Wi-Fi services on long-haul buses and gas station media service, which
indicated  that  the  underperformance  could  be  ascribed  to  i)  the  wide  spread  of  4G  technology  and  affordable  data  plans;  and  ii)  the  depleting  marketing
budget of some of our advertisers. In order to prevent further losses while seizing the opportunities from other components such as air travel media service,
we gradually ceased our operations of Wi-Fi service on long-haul buses and our gas station media services, and scaled down operations in providing Wi-Fi
services on trains.

The operating results of our air travel advertising, gas station advertising business and trains,  and buses are substantially affected by the following factors and
trends.

Demand for Our Advertising Time Slots and Locations

The  demand  for  our  advertising  time  slots  and  locations  for  each  of  the  last  three  fiscal  years  was  directly  related  to  our  customers’  available  advertising
budgets and the attractiveness of our network to our customers. Our network’s attractiveness is largely affected by the coverage of our network, which in turn
depends on the number of intended audience that our network has the ability to reach. In terms of our air travel advertising network, the number of intended
audience we can reach is largely affected by the number of air travelers in China in generally and the scale of our network. The demand for air travel is in turn
affected by general economic conditions, the affordability of air travel in China and certain special events that may attract air travelers into and within China.
Our  customers’  advertising  spending  was  also  particularly  sensitive  to  changes  in  general  economic  conditions.  In  terms  of  our  gas  station  media,  we
gradually  ceased  the  operations  in  early  2018.    The  demand  for  our  time  slots  and  locations  on  airline  Wi-Fi  systems  is  related  to  the  amount  of  our
customers’ advertising spending budget and the attractiveness of our Wi-Fi system as a platform for their advertisements. The amount of available advertising
budget is largely affected by the general economic conditions in China. The attractiveness of our Wi-Fi system as an advertising platform depends on whether
our  Wi-Fi  system  has  the  ability  to  reach  the  advertisers’  intended  audience,  which  will  in  turn  be  affected  by  factors  including  the  number  and  types  of
travelers who will use our Wi-Fi systems and whether advertisements on our Wi-Fi systems can effectively attract the attention of such travelers.

45

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Number of Our Advertising Time Slots and Locations Available for Sale

The number of time slots available for our digital TV screens on airplanes during the period presented is calculated by multiplying the time slots per month
for a given airline by the number of months during the period presented when we had operations on such airline and then calculating the sum of all the time
slots for each of our network airlines. The number of locations available for sale for our light boxes and billboards in gas stations is defined as the number of
light boxes and billboards we operated in Sinopec gas stations.

By increasing the number of airlines in our network, we can increase the number of advertising time slots and locations that we have available to sell. In
addition,  the  length  of  our  advertising  cycle  for  our  digital  TV  screens  can  potentially  be  extended  to  longer  durations  depending  on  demand  on  airline.
However,  advertisers  may  be  unwilling  to  accept  placement  of  their  advertisements  on  a  longer  time  cycle  which  decreases  the  frequencies  of  their
advertisements displayed each day.

The results of our Wi-Fi business can be affected by the number of advertisement time slots and spaces available for sale on our Wi-Fi systems. They are
determined by the number of airplanes within our Wi-Fi service network and the number of advertisement time slots and spaces available on the system for
each airplane. By increasing the number of airplanes within our network, we can increase the number of advertising time slots and locations that we have
available to sell. In addition, we may also increase the total number of advertisement time slots and spaces by increasing the frequency of the advertisements
and designating more space on our Wi-Fi system’s interface for advertising.

Pricing

The average selling price for our advertising time slots is generally calculated by dividing our advertising revenues from these time slots by the number of 30-
second equivalent advertising time slots for digital TV screens on airplanes sold during that period. The average selling price for our gas station media is
calculated by dividing the revenues derived from all the locations sold by the number of locations sold during the period presented. The primary factors that
affect the effective price we charge advertisers for time slots and locations on our network and our utilization rate include the attractiveness of our network to
advertisers, which depends on the number of displays and locations, the number and scale of airplanes in our network, the level of demand for time slots and
locations,  and  the  perceived  effectiveness  by  advertisers  of  their  advertising  campaigns  placed  on  our  network.  We  may  increase  the  selling  prices  of  our
advertising time slots and locations from time to time depending on the demand for our advertising time slots, spaces and locations.

A  significant  percentage  of  the  programs  played  on  our  digital  TV  screens  on  airplanes  included  non-advertising  content  such  as  TV  programs  or  public
service announcements. We did not directly generate revenues from non-advertising content, but we obtained such content from third party content providers.
We believe that the combination of non-advertising content with advertising content makes people more receptive to our programs, which in turn makes the
advertising content more effective for our advertisers. We believe this in turn allows us to charge a higher price for each advertising time slot. We closely
track the program blend and advertiser demand to optimize our ability to generate revenues for each program cycle.

The results of our Wi-Fi business are also affected by the level of pricing for our services.  

46

 
 
 
 
 
 
 
 
 
 
 
 
Utilization Rate

The utilization rate of our advertising time slots is the total time slots sold as a percentage of total time slots available during the relevant period. In order to
provide meaningful comparisons of the utilization rate of our advertising time slots, we generally normalize our time slots into 30-second units for digital TV
screens on airplanes, which we can then compare across network airlines and periods to chart the normalized utilization rate of our network by airlines over
time. The utilization rate of our gas stations media is the total number of locations sold as a percentage of the total number of locations available during the
relevant period. Our overall utilization rate was primarily affected by the demand for our advertising time slots and locations and our ability to increase the
sales of our advertising time slots and locations. We plan to strengthen our sales efforts in these cities by building local sales teams to increase our direct sales
of advertising time slots and locations in these cities and ultimately improve our utilization rate.

Network Coverage and Concession Fees

The demand for our advertising time slots and locations and the effective price we charged advertisers for time slots and locations on our network depended
on the attractiveness and effectiveness of our network as viewed by our advertisers which, in turn, related to the breadth of our network coverage, including
significant coverage on major airlines that advertisers wish to reach. As a result, it has been, and will continue to be, important for us to secure and retain
concession  rights  contracts  to  place  our  programs  on  major  airlines  and  to  increase  the  number  of  programs  we  place  on  those  airlines.  In  addition,  it  is
important for us to secure and maintain the coverage of our gas station network. It is also important to our results of operations of our Wi-Fi business that we
secure and retain these concession rights contracts on commercially advantageous terms.

Concession fees constituted a significant portion of our cost of revenues. Concession fees tend to increase over time, and a significant increase in concession
fees will increase our cost while our revenues may not increase proportionately, or at all. It will therefore be important to our results of operations that we
secure and retain these concession rights contracts on commercially advantageous terms.

Revenues

We mainly generate revenues from the sale of advertising time slots and locations on our advertising network.

(All amounts are in thousands of U.S. dollars, except percentages)

2016

2017

2018

Fiscal Years Ended December 31,

Air Travel Media Network
Gas station Media Network
Other Media
Total revenues
Business tax and other sales tax
Net revenues

  Amount
  $

% of
Total
Revenues

  Amount

% of
Total
Revenues

  Amount

% of
Total
Revenues

73.4%   $
24.2%    
2.4%    

100.0% 

(0.5)%   
99.5%   $

18,702     
4,093     
1,533     
24,328     
(569)    
23,759     

76.9%    
16.8%    
6.3%    
100.0%    
(2.3)%   
97.7%    

22,212     
413     
2,151     
24,776     
(230)    
24,546     

89.7%
1.6%
8.7%
100.0%
(0.9)%
99.1%

12,178     
4,009     
410     
16,597     
(84)    
16,513     

  $

Revenues from Air Travel Media Network and Other Media

Our  air  travel  media  network  revenues  from  operations  in  2016,  2017  and  2018  consisted  of  revenues  from  digital  frames  in  airports  in  the  form  of  TV-
attached digital frames, digital TV screens in airports, digital TV screens on airplanes, traditional media in airports and other revenues in air travel.

47

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
 
   
 
   
 
   
   
   
   
   
 
 
 
 
 
Revenues from our air travel media network accounted for 73.4%, 76.9% and 89.7% of our total revenues for the years ended December 31, 2016, 2017, and
2018 respectively. Our network consisted of six, seven and seven airlines as of December 31, 2016, 2017 and 2018.

Revenues from other media were primarily revenues from our trains Wi-Fi advertising promotion, public account promotion, long-haul Wi-Fi advertising. In
early 2018, we gradually ceased our operations of Wi-Fi service on long-halt buses, and scaled down operations in providing Wi-Fi services on trains.

The most significant factors that directly or indirectly affect our revenues from digital TV screens on airplanes and other revenues in air travel include the
following:

·

·

·

·

·

our ability to retain existing advertisers and attract new advertisers;  

our ability to retain existing concession rights to operate digital TV screens on airplanes and to add additional airlines to our network;  

our ability to continue providing effective advertising solutions that enable advertisers to reach their target audiences;  

the demand in general for air travel advertising; and 

the state of the PRC and global economy.

Revenues from Gas Station Media Network

We started our gas station media network in 2009, when we gained concession rights to develop and operate an outdoor advertising network in Sinopec gas
stations throughout China. Revenues from our gas station media network, consisting of outdoor advertising platforms such as LED screens, billboards and
light boxes at Sinopec gas stations in China, accounted for 24.2%, 16.8% and 1.6% of our total revenues for the years ended December 31, 2016, 2017 and
2018,  respectively.  In  early  2018,  the  management  assessed  the  operational  underperformance  of  our  gas  station  media  service,  which  indicated  that  the
underperformance could be ascribed to i) the wide spread of 4G technology and affordable data plans; and ii) the depleting marketing budget of some of our
advertisers. In order to prevent further losses while seizing the opportunities from other components such as air travel media service, we gradually ceased our
operations of our gas station media services.

Business Tax, Value-added Tax (“VAT”) and Other Sales Related Tax

Our PRC subsidiaries are subject to value-added tax at a rate of 6% on revenues from advertising services and paid after deducting input VAT on purchases.
The net VAT balance between input VAT and output VAT is reflected in the account under input VAT receivable or other taxes payable. In July 2012, the
Ministry of Finance and the State Administration of Taxation jointly issued a circular regarding the pilot collection of VAT in lieu of business tax in certain
areas  and  industries  in  the  PRC,  including  Beijing,  Jiangsu,  Anhui,  Fujian,  Guangdong,  Tianjin,  Zhejiang,  and  Hubei  between  September  and  December
2012.  Also  a  circular  issued  in  May  2013  provided  that  such  VAT  pilot  program  is  rolled  out  nationwide  since  August  2013.  Since  then,  certain  of  our
subsidiaries and VIEs became subject to VAT at the rates of 6% or 3%, on certain service revenues which were previously subject to business tax. Our gross
revenue is presented net of the VAT.

Our net revenue is presented net of such business tax and other sale related taxes. Pursuant to the Circular on Comprehensively Promoting the Pilot Program
of Replacing Business Tax with Value Added Tax promulgated by the Ministry of Finance of China and the State Administration of Taxation of China on
March 23, 2016, which took effect on May 1, 2016, the Chinese government will levy VAT in lieu of business tax on a trial basis across China, and the tax
rate for taxpayers who are service providers, such as us, is 6%.

48

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cost of Revenues

During the periods covered by this report, our cost of revenues consisted primarily of concession fees, agency fees and advertisement publishing fees, and
other costs, including equipment depreciation costs, operating costs and non-advertising content costs. The following table sets forth the major components of
our cost of revenues, both in absolute amounts and as percentages of net revenues for the periods indicated.

Fiscal Years Ended December 31,
(All amounts are in thousands of U.S. Dollars, except percentages)
2017

2018

2016

Net revenues
Cost of revenues
Concession fees
Agency fees and advertisement publishing fees
Others
Total cost of revenues

Concession Fees

  Amount
  $

16,513     

%

  Amount

%

  Amount

%

100.0%   $

23,759     

100.0%   $

24,546     

100.0%

(23,470)    
(4,388)    
(21,184)    
(49,042)    

(142.1)%   
(26.6)%   
(128.3)%   
(297.0)%  $

(28,559)    
(4,675)    
(25,733)    
(58,967)    

(120.2)%   
(19.7)%   
(108.3)%   
(248.2)%  $

(20,976)    
(4,879)    
(6,775)    
(32,630)    

(85.5)%
(19.9)%
(27.6)%
(133.0)%

  $

We incur concession fees to airlines for placing our programs on their digital TV screens and to gas stations for operating our media displays such as light
boxes,  billboards  and  LEDs  and  to  train  administration  authorities  for  Wi-Fi  system  installation  and  operation  rights.  These  fees  constitute  a  significant
portion of our cost of revenues. Most of the concession fees paid to airlines were fixed under the relevant concession rights contracts with escalation clauses,
which required fixed fee increases over each year of the relevant contract, and payments were usually due three or six months in advance.

We began to incur concession fees related to our Wi-Fi business from 2013. We recorded these concession fees in the amount of $5.3 million, $9.5 million
and  $5.1  million  in  2016,  2017  and  2018,  respectively.  The  concession  fee  related  to  Wi-Fi  business  decreased  significantly  in  2018  mainly  due  to  we
gradually ceased our operations of Wi-Fi service on long-haul buses and scaled down operations in providing Wi-Fi services on trains in 2018.

The rest of our concession fees consisted of those related to our non-Wi-Fi business and slightly increased from $18.2 million in 2016 and to $19.1 million in
2017 and decreased to $15.9 million in 2018, the decreased in 2018 was mainly due to we ceased our  gas station business in 2018.

Agency Fees and Advertisement Publishing Fees

From 2016 to 2018, we engaged third-party advertising agencies to help source advertisers from time to time or to help advertise publishing. These third-party
advertising agencies assisted us in identifying and introducing advertisers to us or help us to publish  advertisement. In return, we paid fees to these third-
party agencies if they generated advertising revenues or published  advertisement for us. Fees that we paid to these third-party agencies were calculated based
on  a  pre-set  percentage  of  revenues  generated  from  the  advertisers  by  the  third-party  agencies  and  were  paid  when  payments  were  received  from  the
advertisers. We recorded these agency fees and advertisement  publishing fees as cost of revenues ratably over the period in which the related advertisements
were displayed.

Others

Our other cost of revenues includes the following:

·

Equipment Depreciation.  Generally,  we  capitalized  the  cost  of  our  digital  TV  screens,  light  boxes,  LED  screens  and  billboards  in  the  gas  station
media network and related Wi-Fi equipment and PAD on high-speed trains and recognized depreciation costs on a straight-line basis over the term of
their useful lives, which we estimate to be five years. The primary factors affecting our depreciation costs were the number of digital TV screens,
LED screens in gas stations and Wi-Fi equipment and the unit cost and impairment for those equipment, as well as the remaining useful life of the
equipment. However, the depreciation costs decreased significantly in 2018 due to the impairment on equipment in 2017.

49

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
 
   
 
   
      
  
   
      
  
   
      
  
   
   
   
 
 
 
 
 
 
 
 
 
 
 
 
·

·

Equipment Maintenance Cost. Our maintenance cost consisted of salaries for our network maintenance staff, travel expenses in relation to on-site
visits and monitoring and costs for materials and maintenance in connection with the upkeep of our media network. The primary factor affecting our
equipment maintenance cost was the size of our network maintenance staff.

Non-advertising Content Cost. The programs on the majority of our digital TV screens combine advertising content with non-advertising content,
such as comedy clips, movie and TV series. Our standard programs in airports currently include 40 minutes of non-advertising content during each
hour of  programming  and  are  shown  for  approximately  16  hours  per  day.  Our  in-flight  programs  typically  range  from  approximately  45  to  120
minutes  per  flight,  approximately  40  to  45  minutes  of  which  consist  of  non-advertising  content.  The  majority  of  the  non-advertising  content
broadcast  on  our  network  was  provided  by  third-party  content  providers  such  as  various  local  television  stations  and  television  production
companies. We pay a fixed price for some content. The non-advertising content cost was $0.8 million for the year ended December 31, 2018.

As we gradually ceased our operation of Wi-Fi service on long-haul buses and our gas station media services, scaled down operations in Wi-Fi service on
trains in 2018, our other cost of revenues decreased in 2018 significantly compared to the same for year 2017.

Operating Expenses

During the periods covered by this report, our operating expenses consisted of general and administrative expenses and selling and marketing expenses. The
following table sets forth the two components of our operating expenses, and as a percentage of net revenues for the periods indicated.

Net revenues
Operating expenses
General and administrative expenses
Selling and marketing expenses
Impairment of fixed assets, prepaid equipment cost

2016

  Amount
  $

16,513     

Fiscal Years Ended December 31,
2017

2018

%

  Amount

%

  Amount

%

100.0%   $

23,759     

100.0%   $

24,546     

100.0%

(44,401)    
(12,056)    

(268.9)%   
(73.0)%   

(63,507)    
(12,747)    

(267.3)%   
(53.7)%   

(32,612)    
(7,492)    

(132.9)%
(30.5)%

(2.3)%
(165.7)%

and intangible assets
Total operating expenses

(826)    
(57,283)    

  $

(5.0)%   
(346.9)%  $

(67,342)    
(143,596)    

(283.4)%   
(604.4)%  $

(564)    
(40,668)    

50

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
   
 
   
 
   
      
  
   
      
  
   
      
  
   
   
   
 
 
 
General and Administrative Expenses

Our  general  and  administrative  expenses  consisted  primarily  of  office  and  utility  expenses,  salaries  and  benefits  for  general  management,  finance  and
administrative personnel, allowance for doubtful accounts, depreciation of office equipment, public relations related expenses and other administration related
expenses.

Selling and Marketing Expenses

Our selling and marketing expenses consisted primarily of salaries and benefits for our sales and marketing personnel, office and utility expenses related to
our  selling  and  marketing  activities,  travel  expenses  incurred  by  our  sales  personnel,  expenses  for  the  promotion,  advertisement,  and  other  sales  and
marketing related expenses.

Impairment of fixed assets, prepaid equipment cost and intangible assets

In the second half of 2017, the management was alerted of the trend of recording operational losses continued in providing Wi-Fi
services on trains and long-haul buses and media services on gas station. Meanwhile the management noticed that the willingness
to spend on marketing expenses targeting travelers by trains, buses and gas station was projected strong and growing. Given the
projected  potential  with  exclusivity  to  provide  such  services,  the  management  concluded  that  operations  in  both  business
components should continue and be reviewed in the first quarter of 2018. Upon the scheduled review in the first quarter of 2018, a
flag was risen when the operational loss was widened and the willingness to spend on marketing was depleting and diminishing.
Immediately, the management halted operations in providing Wi-Fi services on long-haul buses and media services in gas station,
scaled down operations in providing Wi-Fi services on trains, and commissioned a comprehensive review on the sustainability of
both  business  components.  Upon  completion  of  the  review,  the  management  exercised  prudently  to  record  impairments  in  both
business components in 2017. In addition, we accrued a fully impairment loss for the leasehold improvement and the construction
in  progress  equipment  of  Tianjin  VR  store  for  the  year  ended  December  31,  2018  because  Tianjin  VR  store  did  not  go  into
operation. 

Taxation

Cayman Islands. We are an exempted company incorporated in the Cayman Islands. The Cayman Islands currently levies no taxes on Islands or corporations
based upon profits, income, gains or appreciation and there is no taxation in the nature of inheritance tax or estate duty.

British Virgin Islands. We are exempted from income tax in the British Virgin Islands on our foreign-derived income. There are no withholding taxes in the
British Virgin Islands.

Hong Kong. Our Hong Kong subsidiary, Air Media (China) Ltd, did not have any assessable profits arising in or derived from Hong Kong for the years ended
December 31, 2016, 2017 and 2018, and accordingly no provision for Hong Kong Profits Tax was made in these years. According to Tax (Amendment) (No.
3) Ordinance 2018 published by Hong Kong government, form April 1, 2018, under the two-tiered profits tax rates regime, the profits tax rate for the first $2
million of assessable profits will be lowered to 8.25% (half of the rate specified in Schedule 8 to the Inland Revenue Ordinance (IRO)) for corporations and
7.5%  (half  of  the  standard  rate)  for  unincorporated  businesses  (mostly  partnerships  and  sole  proprietorships).  Assessable  profits  above  $2  million  will
continue to be subject to the rate of 16.5% for corporations and standard rate of 15% for unincorporated businesses. AN China is qualified to elect the tax rate
of 8.25% as it has no assessable profit in 2018.

PRC. Effective as of January 1, 2008, the EIT Law applies a uniform EIT rate of 25% to all domestic enterprises and foreign-invested enterprises and defines
new  tax  incentives  for  qualified  entities.  Under  the  EIT  Law,  entities  that  qualify  as  HNTE  are  entitled  to  the  preferential  income  tax  rate  of  15%.  A
company’s  status  as  a  HNTE  is  valid  for  three  years,  after  which  the  company  must  re-apply  for  such  qualification  in  order  to  continue  to  enjoy  the
preferential income tax rate.

Chuangyi Technology was recognized as a HNTE and maintained the status that would allow for a reduced 15% tax rate under EIT Law from year 2016 to
2017.  Hence, Chuangyi Technology was subject to an EIT rate of 15%, 15% and 25% in 2016, 2017, and 2018, respectively.

51

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Xi’an Shengshi received the HNTE certificate jointly issued by the competent governmental authorities in Shaanxi Province in September 2014. As such,
Xi’an  Shengshi  was  subject  to  a  preferential  income  tax  rate  of  15%  from  2014  to  2016,  Xi’an  Shengshi  is  subject  to  EIT  at  a  rate  of  25%  from  2017
afterwards.

Shenzhen Yuehang is subject to EIT at a rate of 25% from 2013 afterwards.

Wangfan Linghang qualified for the HNTE at the end of 2017 and entitled to an EIT rate of 15% for the years 2017, 2018 and 2019.

Beijing Yuehang Tianyi qualified for the HNTE in 2018 and entitled to an EIT rate of 15% for the years 2018, 2019 and 2020.

Furthermore,  under  the  EIT  Law,  a  “resident  enterprise,”  which  includes  an  enterprise  established  outside  of  China  with  “de  facto  management  bodies”
located  in  China,  is  subject  to  PRC  income  tax.  The  SAT  issued  the  Notice  Regarding  the  Determination  of  Chinese-Controlled  Overseas  Incorporated
Enterprises  as  PRC  Tax  Resident  Enterprises  on  the  Basis  of  De  Facto  Management  Bodies,  i.e.  SAT  Circular  82,  on  April  22,  2009.  SAT  Circular  82
provides certain specific criteria for determining whether the “de facto management body” of a Chinese-controlled overseas-incorporated enterprise is located
in China.

In  addition,  the  SAT  issued  a  bulletin  on  July  27,  2011  to  provide  more  guidance  on  the  implementation  of  SAT  Circular  82  with  an  effective  date  of
September 1, 2011. The bulletin made clarification in the areas of resident status determination, post-determination administration, as well as competent tax
authorities. It also specifies that when provided with a copy of the Chinese tax resident determination certificate from a resident Chinese controlled offshore
incorporated enterprise, the payer should not withhold 10% income tax when paying the Chinese-sourced dividends, interest, royalties, etc. to the Chinese
controlled offshore incorporated enterprise. Although both SAT Circular 82 and the bulletin only apply to offshore enterprises controlled by PRC enterprises,
not to those that, like our company, are controlled by PRC individuals, the determination criteria set forth in SAT Circular 82 and administration clarification
made in the bulletin may reflect the SAT’s general position on how the “de facto management body” test should be applied in determining the tax residency
status of offshore enterprises and the administration measures should be implemented, regardless of whether they are controlled by PRC enterprises or PRC
individuals.

We do not believe we and our subsidiaries established outside of the PRC are PRC resident enterprises. However, if the PRC tax authorities subsequently
determine that we and our subsidiaries established outside of China should be deemed as a resident enterprise, we and our subsidiaries established outside of
China will be subject to PRC income tax at a rate of 25%. In addition, under the EIT law, dividends generated after January 1, 2008 and payable by a foreign-
invested enterprise in China to its foreign investors who are non-resident enterprises are subject to 10% withholding tax, unless any such foreign investor’s
jurisdiction of incorporation has a tax treaty with China that provides for a different withholding arrangement. The BVI, where Broad Cosmos, our wholly
owned subsidiary and the 100% shareholder of Shenzhen Yuehang, is incorporated, does not have such a tax treaty with China. Air Media (China) Ltd, the
100%  shareholder  of  Chuangyi  Technology  Shenzhen  Yuehang  and  Xi’an  Shengshi,  is  incorporated  in  Hong  Kong.  According  to  the  Mainland  and  Hong
Kong Special Administrative Region Arrangement on Avoiding Double Taxation or Evasion of Taxation on Income agreed between China and Hong Kong in
August 2006, dividends paid by a foreign-invested enterprise in China to its direct holding company in Hong Kong will be subject to withholding tax at a rate
of  5%  (if  the  foreign  investor  owns  directly  at  least  25%  of  the  shares  of  the  foreign-invested  enterprise).  However,  if  the  Hong  Kong  company  is  not
considered to be the beneficial owner of dividends paid to it by its PRC subsidiaries under a tax notice promulgated on October 27, 2009 and the bulletin
No.30 of 2012, such dividends would be subject to withholding tax at a rate of 10%. See “Item 3. Key Information — D. Risk Factors — Risks Related to our
Business — Dividends payable to us by our wholly-owned operating subsidiaries may be subject to PRC withholding taxes, or we may be subject to PRC
taxation on our worldwide income, and dividends distributed to our investors may be subject to more PRC withholding taxes under the PRC tax law.”

Critical Accounting Policies  

We prepare our financial statements in conformity with U.S. GAAP, which requires us to make estimates and assumptions that affect our reporting of, among
other things, assets and liabilities, contingent assets and liabilities and revenues and expenses. We continually evaluate these estimates and assumptions based
on the most recently available information, our own historical experiences and other factors that we believe to be relevant under the circumstances. Since our
financial reporting process inherently relies on the use of estimates and assumptions, our actual results could differ from our expectations. This is especially
true with some accounting policies that require higher degrees of judgment than others in their application. We consider the policies discussed below to be
critical to an understanding of our audited consolidated financial statements because they involve the greatest reliance on our management’s judgment.

52

 
 
 
 
 
 
 
 
 
 
 
 
 
Revenue Recognition

On  January  1,  2018,  the  Company  adopted  ASC Topic  606,  “Revenue  from  Contracts  with  Customers”,  applying  the  modified  retrospective  method.  The
adoption did not result in a material adjustment to the accumulated deficit as of January 1, 2018.

In accordance with ASC Topic 606, revenues are recognized when control of the promised goods or services is transferred to the Company’s customers, in an
amount that reflects the consideration the Company expects to be entitled to in exchange for those goods or services. In determining when and how much
revenue is recognized from contracts with customers, the Company performs the following five-step analysis: (1) identify the contract(s) with a customer; (2)
identify the performance obligations in the contract; (3) determine the transaction price; (4) allocate the transaction price to the performance obligations in the
contract; (5) recognize revenue when (or as) the entity satisfies a performance obligation.

The Company’s contracts with customers do not include multiple performance obligations, significant financing component and any variable consideration.

The Company is a principal as it controls the specified good or service before that good or service is transferred to a customer. The Company is primarily
responsible for fulfilling the promise to provide the specified good or service, has inventory risk before the specified good or service has been transferred to a
customer and has discretion in establishing the price for the specified good or service.

Generally, the Company recognizes revenue under ASC Topic 606 for each type of its performance obligation either over time (generally, the transfer of a
service) or at a point in time (generally, the transfer of content) as follows:

The Company's revenues are derived from selling advertising time slots on the Company's advertising networks. For the years ended December 31, 2016,
2017 and 2018, the advertising revenues were generated from air travel media network including TV-attached digital frames in airports, digital TV screens in
airports, digital TV screens on airlines, gas station media network and other media network such as on-train and on long-haul bus Wi-Fi.

Revenue by service categories:

Revenues from operations:

Air Travel Media Network
Gas Station Media Network
Other Media

2016

For the years ended December 31,
2017
(In thousands of U.S. Dollars)

2018

  $

  $

12,178    $
4,009     
410     
16,597    $

18,702    $
4,093     
1,533     
24,328    $

22,212 
413 
2,151 
24,776 

Air Travel Media Network:  Through  air  travel  media  network,  revenues  were  generated  from  digital  frames  in  airports  in  the  form  of  TV-attached  digital
frames, digital TV screens in airports, digital TV screens on airplanes. There are also other revenues in air travel mainly include revenues from the display of
media  contents  in  air  travel.  For  the  advertising  business,  the  Company  typically  signs  standard  contracts  with  its  advertising  clients,  who  require  the
Company to run the advertiser's advertisements on the Company's network in airports, airlines for a period of time which is the only performance obligation
for a fixed price agreed in the contracts without variable considerations. The Company recognizes advertising revenues ratably over the service period for
which the advertisements are displayed, so long as collection remains probable.

Gas Station Media Network: Through gas station media network, the Company sells advertising time slots through digital TV screens in gas stations which is
the only performance obligation included in the contracts. The Company signs fixed fee contracts with the end customers or agencies for a specified period.
The revenue is recognized on a straight-line basis over the specified period. This business is ceased in 2018 and no continuing revenue will be generated from
gas station in following years.

Other Media: Through other media network such as on-train and on long-haul bus Wi-Fi, the Company provides Wechat public account promotion through
Wi-Fi  network  and  advertising  and  promotion  articles  publishing  on  both  self-owned  and  third  parties’  public  accounts.  Wechat  public  account  is  an
application account applied by individual, business or enterprise on the Wechat Public Platform through which communication and interaction with specific
groups of words, pictures, voice and video can be achieved. For the public account promotion business, the passengers in the trains could connect to Wi-Fi for
free via the Company's Wi-Fi equipment after registered as a member to that public account as a follower in WeChat. The Company charges a fix rate per new
member and collects service fee from the client who owns the public accounts. The Company typically signs standard contracts with its clients, who require
the Company to promote their public accounts which is the only performance obligation defined in the contracts, and recognizes public account promotion
revenue by the quantities of members over the performance period multiplied by unit price defined in the contract. For the advertising and promotion articles
publishing business, the Company has developed a public accounts pool which have already accumulated hundreds of and thousands of registered users (there
are both self-owned and third parties’ public accounts). The Company typically signs standard contracts with its clients, who require the Company to publish
advertising articles on the public accounts to take advantage of the existing users and recognizes advertising revenues by numbers of articles published on
public accounts and the unit price that defined in the contract which differs on the basis of user numbers of selected public accounts.

Deferred Revenue

Prepayments from customers for advertising service are deferred when corresponding performance obligation is not satisfied and recognized as revenue when
the advertising services are rendered. The balance of deferred revenue as of December 31, 2018 is $2.0 million, the majority of which is $1.1 million for the
unsatisfied performance obligation with two customers with contracts amount of $5.7 million.

Nonmonetary exchanges

The  Company  occasionally  exchanges  advertising  time  slots  and  locations  with  other  entities  for  assets  or  services,  such  as
equipment and other assets. The amount of assets and revenue recognized is based on the fair value of the advertising provided or

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
    
    
  
   
   
 
 
 
 
 
 
 
 
the fair value of the transferred assets, whichever is more readily determinable. There were no revenue recognized for nonmonetary
transactions were for the years ended December 31, 2016, 2017 and 2018. No direct costs are attributable to the revenues.

Concession Fees

The  Company  enters  concession  right  agreements  with  vendors  such  as  airlines,  railway  bureaus  and  petroleum  companies,  under  which  The  Company
obtains the right to use the spaces or equipment of the vendors to display the advertisements.

Fees under concession right agreements are usually due every three, six or twelve months. Payments made are recorded as current assets and current liabilities
according  to  the  respective  payment  terms.  Most  of  the  concession  fees  with  airlines  and  railway  bureaus  are  fixed  with  escalation,  which  means  a  fixed
increase  over  each  year  of  the  agreements.  The  total  concession  fee  under  the  concession  right  agreements  with  airlines  is  charged  to  the  consolidated
statements of operations on a straight-line basis over the agreement periods, which is generally between three to five years.

The fee structure of the concession right agreement with the petroleum companies is based on the actual number of developed gas stations and associated
standard annual concession fee for each developed gas station. Each gas station has its specific lease term starting from the time when it is actually put into
operation. The calculation of rental payments is based on how many months the gas stations are actually put into operation during the year and the standard
annual concession fee determined based on the location of the gas station. The amount of annual concession fee to-be-paid is determined by an actual incurred
concession fee or a fixed minimum payment, if any, based on negotiation with the petroleum company.

In 2018, we ceased our long-haul buses Wi-Fi service operations and gas station media services, and scaled down operations in providing Wi-Fi services on
trains. The concession fees due to the petroleum companies will be settled by providing equipment and future free service. Other prepaid concession fees
made to railway bureaus are returned or to be returned in the future.

53

 
 
 
 
 
 
 
 
Agency Fees and Advertisement  Publishing Fees

The Company pays fees to advertising agencies for identifying and introducing advertisers to us and assisting in advertisement publishing based on a certain
percentage of revenues made through the advertisement agencies upon receipt of payment from advertisers. The agency fees and advertisement publishing
fees are charged to cost of revenues in the consolidated statements of operations ratably over the period in which the advertisement is displayed. Prepaid and
accrued agency fees and advertisement publishing fees are recorded as current assets and current liabilities according to relative timing of payments made and
advertising service provided.

Allowance for Doubtful Accounts

The Company conducts credit evaluations of clients and generally does not require collateral or other security from clients. The
Company establishes an allowance for doubtful accounts based upon estimates, historical experience and other factors surrounding
the credit risk of specific clients and utilizes both specific identification and a general reserve to calculate allowance for doubtful
accounts. The amount of receivables ultimately not collected by the Company has generally been consistent with expectations and
the  allowance  established  for  doubtful  accounts.  If  the  frequency  and  amount  of  customer  defaults  change  due  to  the  clients'
financial condition or general economic conditions, the allowance for uncollectible accounts may require adjustment. As a result,
the Company continuously monitors outstanding receivables and adjusts allowances for accounts where collection may be in doubt.

Impairment of long-lived assets

Long-lived  assets  held  and  used  by  us  are  reviewed  for  impairment  whenever  events  or  changes  in  circumstances  indicate  that  the  carrying  value  of  such
assets may not be fully recoverable. It is possible that these assets could become impaired as a result of technology, economy or other industry changes. If
circumstances  require  a  long-lived  asset  or  asset  group  to  be  tested  for  possible  impairment,  we  first  compare  undiscounted  cash  flows  expected  to  be
generated by that asset or asset group to its carrying value. If the carrying value of the long-lived asset or asset group is not recoverable on an undiscounted
cash flow basis, an impairment is recognized to the extent that the carrying value exceeds its fair value. Fair value is determined through various valuation
techniques,  including  discounted  cash  flow  models,  relief  from  royalty  income  approach,  quoted  market  values  and  third-party  independent  appraisals,  as
considered necessary.

We make various assumptions and estimates regarding estimated future cash flows and other factors in determining the fair values of the respective assets.
The  assumptions  and  estimates  used  to  determine  future  values  and  remaining  useful  lives  of  long-lived  assets  are  complex  and  subjective.  They  can  be
affected by various factors, including external factors such as industry and economic trends, and internal factors such as our business strategy and its forecasts
for specific market expansion

Income Taxes

Deferred  income  taxes  are  recognized  for  temporary  differences  between  the  tax  basis  of  assets  and  liabilities  and  their  reported  amounts  in  the  financial
statements, net operating loss carry forwards and credits, by applying enacted statutory tax rates applicable to future years. Deferred tax assets are reduced by
a valuation allowance when, in the opinion of management, it is more likely than not that some portion or all of the deferred tax assets will not be realized.
Current income taxes are provided for in accordance with the laws and regulations applicable to us as enacted by the relevant tax authorities.

54

 
 
 
 
 
 
 
 
 
 
 
 
 
The impact of an uncertain income tax position on the income tax return must be recognized at the largest amount that is more-likely-than not to be sustained
upon audit by the relevant tax authorities. An uncertain income tax position will not be recognized if it has less than a 50% likelihood of being sustained.
Additionally, the Company classifies the interest and penalties, if any, as a component of the income tax expense. According to the PRC Tax Administration
and  Collection  Law,  the  statute  of  limitations  is  three  years  if  the  underpayment  of  taxes  is  due  to  computational  errors  made  by  the  taxpayer  or  the
withholding agent. The statute of limitations is extended to five years under special circumstances, where the underpayment of taxes is more than RMB 100.
In the case of transfer pricing issues, the statute of limitation is ten years. There is no statute of limitation in the case of tax evasion. According to Hong Kong
Inland Revenue Department, the statute of limitation is six years if any company chargeable with tax has not been assessed or has been assessed at less than
the proper amount, the statute of limitation is extended to 10 years if the underpayment of taxes is due to fraud or willful evasion. In 2018, the Company
incurred penalties of $4.3 million related to underpayment or delayed payment for income tax expense of previous years. The tax penalty of $2,664 is charged
for  one-year  delay  of  income  tax  payment  of  2015  rising  from  the  gain  on  transferring  75%  equity  of  AM  Advertising  and  the  tax  penalty  of  $1,660  is
charged for the unpaid income tax expense of 2016 for the deduction of bad debt allowance from taxable income before tax without chasing up for debt and
filing  a  special  declaration  of  loss  in  asset.  As  of  December  31,  2018,  all  the  penalties  have  been  paid  off.  For  the  transferring  20.32%  equity  of  AM
Advertising of which the industrial and commercial registration procedure was completed in December 2018, the Company has filed this equity transaction in
the  first  quarter  tax  return  filling  in  early  2019.  For  the  deduction  of  bad  allowance,  the  inspection  method  has  been  changed  from  filing  a  declaration  to
reporting  the  loss  by  taxpayer.  Hence,  the  Company  did  not  have  any  material  outstanding  interest  or  penalties  associated  with  tax  positions  nor  did  the
Company have any significant unrecognized tax positions will materially change over the next 12 months. The Company is not currently under examination
by an income tax authority, nor has been notified that an examination is contemplated.

Our Results of Operations

The following table sets forth a summary of our consolidated results of operations for the periods indicated. This information should be read together with our
consolidated financial statements, including the related notes that appear elsewhere in this annual report. We do not believe our historical consolidated results
of operations are indicative of our results of operations you may expect for any future period.

55

 
 
  
 
 
 
 
2016

Years Ended December 31,
2017
(In thousands of U.S. Dollars, except 
share, per share and per ADS data)

2018

Consolidated Statements of Operations Data:
Revenues:
Air Travel Media Network
Gas Station Media Network
Other Media
Total revenues
Business tax and other sales tax
Net revenues
Cost of revenues
Gross loss
Operating expenses:
Selling and marketing
General and administrative
Impairment of fixed assets, prepaid equipment cost and intangible assets
Total operating expenses
Loss from operations
Interest income (expense), net
Loss from and impairment on long-term investments
Other income, net
Loss from operations before income taxes
Income tax expenses
Net loss
Less: Net loss attributable to noncontrolling interests
Net loss attributable to AirMedia Group Inc.’s shareholders

Year Ended December 31, 2018 Compared to Year Ended December 31, 2017

12,178     
4,009     
410     
16,597     
(84)    
16,513     
(49,042)    
(32,529)    

(12,056)    
(44,401)    
(826)    
(57,283)    
(89,812)    
843     
(33)    
4,243     
(84,759)    
(4,483)    
(89,242)    
(23,617)    
(65,625)   $

18,702     
4,093     
1,533     
24,328     
(569)    
23,759     
(58,967)    
(35,208)    

(12,747)    
(63,507)    
(67,342)    
(143,596)    
(178,804)    
2,645     
(2,603)    
214     
(178,548)    
(633)    
(179,181)    
(22,705)    
(156,476)   $

22,212 
413 
2,151 
24,776 
(230)
24,546 
(32,630)
(8,084)

(7,492)
(32,612)
(564)
(40,668)
(48,752)
(106)
(52,337)
7,926 
(93,269)
(150)
(93,419)
(3,322)
(90,097)

  $

Net Revenues. Our net revenues increased by 3.3% to $24.5 million in 2018 from $23.8 million in 2017. The increase was primarily due to the increase in
revenues from air travel media network, which was offset by the decrease in gas station media network.

Revenues from air travel media network: Revenues from air travel media network increased by 18.8% from $18.7 million in 2017 to $22.2 million in 2018.
Among our revenues from air travel media network, revenues from digital TV screens on airplanes were $15.3 million and $20.9 million in 2017 and 2018,
respectively. The increase in revenues from digital TV screens on airplanes mainly resulted from a strong advertising market and an increase in advertisers’
demand for digital TV screens.

Revenues from the gas station media network: Revenues from the gas station media network decreased by 89.9% from $4.1 million in 2017 to $0.4 million in
2018 because we gradually ceased our gas station media services in 2018.

Revenues from other media: Revenues from other media were primarily revenues from our trains Wi-Fi advertising promotion and public account promotion.
Revenues  from  other  media  increased  by  40.3%  year-over-year  to  $2.2  million  in  2018  from  $1.5  million  in  2017,  primarily  due  to  an  increase  of  $0.34
million in revenues from trains Wi-Fi advertising promotion.

Cost of Revenues. Our cost of revenues decreased by 44.7% to $32.6 million in 2018 from $59.0 million in 2017. Our cost of revenues as a percentage of our
net  revenues  decreased  to  133.0%  in  2018  from  248.2%  in  2017.  This  decrease  was  mainly  due  to  the  significant  decrease  in  our  depreciation  costs  and
concession fee costs. Depreciation costs, as one of the major component in our cost of revenue, decreased significantly by 99.6% to $44 thousand in 2018
from $10.1 million in 2017, resulting from the impairment of equipment recorded in 2017. Concession fees decreased by 26.6% to $21.0 million in 2018 from
$28.6 million in 2017. Concession fees as a percentage of net revenues decreased to 85.5% in 2018 from 120.2% in 2017. The concession fees of long-haul
buses, gas station and trains decreased significantly because we ceased operation of Wi-Fi service on long-haul buses and our gas station media services, and
scaled  down  operations  in  providing  Wi-Fi  services  on  trains.  The  concession  fees  of  airline  increased  by  $0.6  million  due  to  the  development  of  airline
business with concession cost increase by $6 million, which is offset by the concession cost reduction due to the refund received from one Airline company of
$5.4 million.

Operating Expenses. Our operating expenses decreased by 71.7% to $40.7 million in 2018 from $143.6 million in 2017.

56

 
 
 
 
 
 
 
   
   
 
 
 
 
   
      
      
  
   
      
      
  
   
   
   
   
   
   
   
   
   
      
      
  
   
   
   
   
   
   
   
   
   
   
   
   
 
 
 
 
 
 
 
 
 
 
·

·

·

Selling and Marketing Expenses. Our selling and marketing expenses decreased by 41.2% to $7.5 million in 2018 from $12.7 million in 2017. Our
selling and marketing expenses mainly consisted of $5.0 million and $8.4 million staff expenses for the year ended December 31, 2018 and 2017,
respectively.  The  selling  expense  decreased  significantly  primarily  due  to  the  decrease  of  staff  numbers,  because  we  ceased  operations  of  Wi-Fi
service on long-haul buses and our gas station media services, and scaled down operations in providing Wi-Fi services on trains in early 2018.

General and Administrative Expenses. Our general and administrative expenses decreased by 48.6% to $32.6 million in 2018 from $63.5 million in
2017. This decrease was mainly due to the significant decrease in our bad debt expenses and staff expenses. Our bad debt expenses decreased to
$11.9 million in 2018 from $37.3 million in 2017. The staff expenses decreased to $11.3 million in 2018 from $12.5 million in 2017, because we
ceased our operations of Wi-Fi service on long-haul buses and gas station media services, and scaled down operations in providing Wi-Fi services on
trains in early 2018. The professional service fee decreased to $2.0 million in 2018 from $6.2 million in 2017 primarily due to (1) a $1.8 million
financing costs paid in 2017; and (2) the decrease of business consulting fee in 2018.

Impairment of  fixed  assets,  prepaid  equipment  cost  and  intangible  assets. Our  impairment  of  fixed  assets,  prepaid  equipment  cost  and  intangible
assets  decreased  by  99.2%  to  $0.6  million  in  2018  from  $67.3  million  in  2017,  primarily  resulting  from  the  impairment  due  to  the  unexpected
operational underperformance from Wi-Fi services on trains, long-haul buses and gas station media service in 2017 of $66.8 million.

Loss from Operations. We recorded a loss from operations of $48.8 million in 2018, as compared to a loss from operations of $178.8 million in 2017 as a
cumulative result of the above factors.

Year Ended December 31, 2017 Compared to Year Ended December 31, 2016

Net Revenues. Our net revenues increased by 43.9% to $23.8 million in 2017 from $16.5 million in 2016. The increase was primarily due to the increase in
revenues from air travel media network.

Revenues from air travel media network: Revenues from air travel media network increased by 53.6% from $12.2 million in 2016 to $18.7 million in 2017.
Among our revenues from air travel media network, revenues from digital TV screens on airplanes were $10.3 million and $15.3 million in 2016 and 2017,
respectively. The increase in revenues from digital TV screens on airplanes mainly resulted from a strong advertising market and an increase in advertisers’
demand for digital TV screens.

Revenues from the gas station media network: Revenues from the gas station media network increased by 2.1% from $4.0 million in 2016 to $4.1 million in
2017 due to a stable advertising market.

Revenues from other media: Revenues from other media were primarily revenues from our trains and buses Wi-Fi network and film distribution business.
Revenues  from  other  media  increased  by  273.9%  year-over-year  to  $1.5  million  in  2017  from  $0.4  million  in  2016,  primarily  due  to  an  increase  of  $0.6
million and $0.4 million in advertising market through trains and buses Wi-Fi network, respectively.

Cost of Revenues. Our cost of revenues increased by 20.2% to $59.0 million in 2017 from $49.0 million in 2016. Our cost of revenues as a percentage of our
net revenues decreased to 248.2% in 2017 from 297% in 2016. This increase was mainly due to the significant increase in our revenues. Concession fees, as
one of the major component in our cost of revenue, increased by 21.7% to $28.6 million in 2017 from $23.5 million in 2016. Concession fees as a percentage
of net revenues decreased to 120.2% in 2017 from 142.1% in 2016. We continued to pay much of the related concession fees in 2017 due to our obligations
under the concession rights. As of the date of this annual report, concession rights contracts in connection with the business that we no longer operate have
either expired or been transferred to third parties. We expect to incur concession fee costs associated only with the business lines of digital TV screens on
airplanes, gas station media and our Wi-Fi business.

Operating Expenses. Our operating expenses increased by 150.7% to $143.6 million in 2017 from $57.3 million in 2016. Our total operating expenses in
2016 included share-based compensation expenses of $0.8 million while our total operating expenses in 2017 included share-based compensation expenses of
$0.3 million.

·

·

Selling and Marketing Expenses. Our selling and marketing expenses increased by 5.7% to $12.7 million in 2017 from $12.1 million in 2016. For
2017, our selling and marketing expenses mainly consisted of $8.4 million staff expenses.

General  and  Administrative  Expenses.  Our  general  and  administrative  expenses  increased  by  43.0%  to  $63.5  million  (including  $0.3  million  of
share-based compensation expenses) in 2017 from $44.4 million (including $0.8 million of share-based compensation expenses) in 2016, primarily
due to approximately $37.2 million in bad debt expenses incurred in 2017. During 2016, we incurred bad debt expenses of $12.7 million.

57

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
·

Impairment  of  fixed  assets,  prepaid  equipment  cost  and  intangible  assets.  Our  impairment  of  fixed  assets,  prepaid  equipment  cost  and  intangible
assets increased by 8,052.8% to $67.3 million in 2017 from $0.8 million in 2016, primarily due to the unexpected operational underperformance
from Wi-Fi services on trains, long-haul buses and gas station media service in 2017.

Loss from Operations. We recorded a loss from operations of $178.8 million in 2017, as compared to a loss from operations of $89.8 million in 2016 as a
cumulative result of the above factors.

Share-based Compensation

2012 Share incentive plan

On November 30, 2012, the Board of Directors adopted 2012 Share Incentive Plan (the “2012 Option Plan”), which allows the Company to grant options to
its employees and directors to purchase up to 6,000,000 ordinary shares of the Company subject to vesting requirement.

On November 1 and November 30, 2012, the Company granted 20,000 options to a consultant under the 2007 Option Plan and 60,000 options under the 2012
Option Plan to purchase the Company’s ordinary shares at an exercise price of $1.11 per share. 20,000 share options were vested immediately and one-third
of the 60,000 share options vested on February 1, May 1 and August 1, 2013, respectively.

On June 1 and August 1, 2014, the Company granted 2,376,620 options and 140,000 options to its employees under the 2012 Option Plan to purchase the
Company’s ordinary shares at an exercise price of $1.025 and $1.045 per share, respectively. One twelfth of these options will vest each quarter through June
1, 2017 and August 1, 2017, respectively. The expiration date will be 5 years from the grant dates.

On  October  13,  2014,  an  employee  terminated  his  employment  with  the  Company  but  continued  to  provide  service  as  a  nonemployee  consultant.  50,000
options granted to him on August 1, 2014 were not modified in connection with the change in status, but future service is still necessary to earn the award.
The compensation cost was measured as if the options were newly granted at the date of the change of status. The incremental share-based compensation
expense  for  the  year  ended  December  31,  2014  was  not  material.  On  October  31,  2015,  the  consultant  service  contract  terminated.  Of  the  50,000  options
granted to him, 20,830 were vested through the service period end and the expiration date of the vested options was modified from August 1, 2019 to January
31, 2016. The rest 29,170 unvested options were cancelled at the service period end.

58

 
 
 
 
 
 
 
 
 
 
 
 
On May 12, 2015, the Company granted 660,000 options its employees under the 2012 Option Plan to purchase the Company’s ordinary shares at an exercise
price of $1.675 per share. One twelfth of these options will vest each quarter through May 12, 2018. The expiration date will be 5 years from the grant date.

On June 15, 2015, an employee terminated his employment with the Company but continued to provide service as a nonemployee consultant. 200,000 options
granted  to  him  on  June  1,  2014  were  not  modified  in  connection  with  the  change  in  status,  but  future  service  is  still  necessary  to  earn  the  award.  The
compensation cost was measured as if the options were newly granted at the date of the change of status. The incremental share-based compensation expense
for the year ended December 31, 2015 was not material.

On October 31, 2015, an employee terminated his employment with the Company but continued to provide service as a nonemployee consultant. 100,000
options granted to him on May 12, 2015 were not modified in connection with the change in status, but future service is still necessary to earn the award. The
compensation cost was measured as if the options were newly granted at the date of the change of status. The incremental share-based compensation expense
for the year ended December 31, 2015 was not material.

On December 31, 2015, two consultants resigned. Of the 200,000 options granted to one of them on May 12, 2015, 3,332 were vested through the date of
resignation. The expiration date of the vested options was modified from May 12, 2020 to May 31, 2016. For the rest 166,668 unvested options, one twelfth
of the total granted options will still vest on February 12, 2016 following the original vesting schedule and the rest 150,002 options were cancelled on the date
of resignation. The fair value of the stock options, which was $1.12 per share as of the modification date, was estimated using the Black-Scholes model. The
incremental compensation cost of the modified award was immaterial for the year ended December 31, 2015. Of the 100,000 options granted to the other
consultant on May 12, 2015, 16,664 were vested through the date of resignation. The expiration date of the vested options was modified from May 12, 2020
to January 31, 2016, and the 83,336 unvested options were cancelled on the date of resignation.

On March 10, 2016, the Board of Directors approved to extend the expiration dates of the 685,000 options from various original expiration dates in March
and April 2016 to December 31, 2016. Modified awards are viewed as an exchange of the original award for a new award. The fair value of the stock options
of $1.67 as of the modification dates was estimated using the Black-Scholes model. The incremental share-based compensation expense for the year ended
December 31, 2016 was not material.

On  July  10,  2016,  Board  of  Directors  approved  to  extend  the  expiration  dates  of  the  2,139,918  options  from  original  expiration  date  of  July  11,  2016  to
December 31, 2016. Modified awards are viewed as an exchange of the original award for a new award. The fair value of the stock options of $0.38 as of the
modification date was estimated using the Black-Scholes model. The incremental share-based compensation expense of $79,000 was recognized for the year
ended December 31, 2016.

For the year ended December 31, 2016, four employees terminated their employment relationships with us, but continued to provide service as nonemployee
consultant. Their options were not modified in connection with the change in status, but future service is still necessary to earn the award. The compensation
cost was measured as if the options were newly granted at the date of the change of status. The incremental share-based compensation expense of $0.2 million
was recognized for the year ended December 31, 2016.

The fair value of each option granted was estimated on the date of grant/modification using the Black-Scholes option pricing model.

We recorded share-based compensation of $0.8 million, $0.3 million and $0.1 million for the years ended December 31, 2016, 2017 and 2018, respectively.

59

 
 
 
 
 
 
 
 
 
 
 
 
 
Inflation

Historically  inflation  has  not  had  a  significant  effect  on  our  business.  According  to  the  National  Bureau  of  Statistics  of  China,  the  year-over-year  percent
changes in the consumer price index for December 2016, 2017 and 2018 was increase of 2.1%, 1.8%, and 1.9%, respectively.

Although it has not materially impacted our results of operations in 2018, we can provide no assurance that we will not be affected in the future by potentially
higher rates of inflation in China. For example, certain operating costs and expenses, such as employee compensation and office operating expenses, may
increase  as  a  result  of  higher  inflation.  Additionally,  because  a  substantial  portion  of  our  assets  consists  of  cash  and  cash  equivalent,  high  inflation  could
significantly reduce the value and purchasing power of these assets. We are not able to hedge our exposure to higher inflation in China.

Recently Issued Accounting Pronouncements

See Item. 17 of Part III, “Financial Statements—Note 2—Summary of significant accounting policies—Recent issued accounting standard.”

B.

Liquidity and Capital Resources

To date, we have financed our operations primarily through internally generated cash, the sale of preferred shares in private placements and the proceeds we
received from our initial public offering.

The Company incurred losses from operations of $178.8 million and $48.8 million for the years ended December 31, 2017 and 2018. As of December 31,
2018,  the  Company  had  shareholders’  deficit  of  $262.4  million.  The  Company  had  negative  cash  flows  from  operating  activities  for  the  years  ended
December  31,  2017  and  2018  of  $58.6  million  and  $19.8  million,  respectively.  These  conditions  raise  substantial  doubt  about  the  Company’s  ability  to
continue as a going concern.

The  Company  intends  to  meet  the  cash  requirements  for  the  next  12  months  from  the  issuance  date  of  this  report  through  a  combination  of  bank  loan,
financing by way of private placements, friends, family and business associates and management financial support. The Company will focus on the following
activities:

·

·

·

The Company plans to strengthen the air Wi-Fi business to drive its revenues and bring in cash from operation;

The Company is focusing on improving operation efficiency and cost reduction to standardize operations, enhance internal controls, and create
synergy of the Company’s resources;

The Company has also acquired the financial support letter from Mr. Man Guo and Mr. Qing Xu, who have expressed the willingness and intention
to provide the necessary financial support to the Company, so as to enable the Company to meet its liabilities as and when it falls due and to carry on
its business without a significant curtailment of operations for the next 12 months from the issuance date of this report.

As a result, management prepared the consolidated financial statements assuming the Company will continue as a going concern. As described above, the
Company has a significant working capital deficiency, has incurred significant losses and needs to raise additional funds to meet its obligations and sustain its
operations.  These  conditions  raise  substantial  doubt  about  the  Company's  ability  to  continue  as  a  going  concern.  Management's  plans  in  regard  to  these
matters are also described above. However, there is no assurance that the measures above can be achieved as planned. The consolidated financial statements
do not include any adjustments that might result from the outcome of this uncertainty.

We  generally  deposit  our  excess  cash  in  interest  bearing  bank  accounts.  Although  we  consolidate  the  results  of  our  VIEs  in  our  consolidated  financial
statements,  we  can  only  receive  cash  payments  from  them  pursuant  to  our  contractual  arrangements  with  them  and  their  shareholders.  See  “Item  4.
Information on the Company — C. Organizational Structure.” Our principal uses of cash primarily include capital expenditures, contractual concession fees,
business acquisitions, share repurchases, and other investments and, to a lesser extent, salaries and benefits for our employees and other operating expenses.
We expect that these will remain our principal uses of cash in the foreseeable future. We may also use additional cash to fund strategic acquisitions.

60

 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
Cash Flow

The following table shows our cash flows with respect to operating activities, investing activities and financing activities for the years ended December 31,
2016, 2017 and 2018:

Net cash used in  operating activities
Net cash provided by (used in) investing activities
Net cash provided by (used in) financing activities
Effect of exchange rate changes
Net increase/(decrease) in cash, cash equivalents and restricted cash
Cash, cash equivalents and restricted cash at the beginning of the year
Cash, cash equivalents and restricted cash at the end of the year

Operating Activities 

Years Ended December 31,
2017

2016

2018

(103,610)    
130,582     
11,130     
(7,515)    
30,587     
86,960     
117,547     

(58,570)    
(47,166)    
874     
5,787     
(99,075)    
117,547     
18,472     

(19,774)
20,096 
(1,695)
(1,560)
(2,933)
18,472 
15,539 

Net cash used in operating activities was $19.8 million for the year ended December 31, 2018. Net cash used in operating activities was primarily attributable
to (1) a net loss of $93.4 million adjusted by non-cash loss and impairment on long-term investment of $52.3 million and bad debt expenses of $11.9 million,
and (2) a decrease in accrued expenses and other current liabilities of $3.7 million, partially offset by (1) an increase in accounts payable of $7.8 million, and
(2) a decrease in prepaid concession fees of $5.1 million.

Net cash used in operating activities was $58.6 million for the year ended December 31, 2017. Net cash used in operating activities was primarily attributable
to (1) a net loss of $179.2 million adjusted by non-cash loss and impairment of property and equipment, prepaid equipment cost and intangible assets of $67.3
million, bad debt expenses of $37.3 million and depreciation and amortization of $12.0 million, and (2) a decrease of other non-current assets of $1.3 million.

Net  cash  used  in  operating  activities  was  $103.6  million  for  the  year  ended  December  31,  2016.  Net  cash  used  in  operating  activities  was  primarily
attributable to (1) a net loss of $89.2 million adjusted by non-cash bad debt expenses of $12.7 million and depreciation and amortization of $13.0 million, (2)
a decrease in income tax payable of $27.4 million and (3) a decrease due to related parties of $15.0 million. 

Investing Activities

Net cash provided by investing activities for the year ended December 31, 2018 amounted to $20.1 million.  The amount of net cash provided by investing
activities was principally attributable to the disposal of long-term investment of $22.6 million, partially offset by the purchase of property and equipment of
$3.6 million.

Net  cash  used  in  investing  activities  for  the  year  ended  December  31,  2017  amounted  to  $47.2  million.  The  amount  of  net  cash  provided  by  investing
activities was principally attributable to (1) loan to third parties of $22.6 million, (2) purchase of long term investment of $17.4 million and (3) purchase of
property and equipment of $7.2 million.

Net cash provided by investing activities for the year ended December 31, 2016 amounted to $130.6 million.  The amount of net cash provided by investing
activities  was  principally  attributable  to  receipt  of  consideration  receivable  of  $196  million  as  a  result  of  disposition  of  our  75%  equity  interest  in  AM
Advertising in 2015, partially offset by (1) purchase of property and equipment of $21.6 million, (2) purchase of equity in subsidiary of $32.8 million and (3)
increase of loan to third parties by $17.1 million.

61

 
 
 
 
 
 
 
 
 
   
   
 
   
   
   
   
   
   
   
 
 
  
 
 
 
 
 
 
 
 
 
 
Capital Expenditures

Our capital expenditures were made primarily to purchase equipment for our network, including network construction for our gas station media network and
our Wi-Fi business.

Our capital expenditures were $21.6 million in 2016, $7.2 million in 2017, and $3.6 million in 2018, respectively.

Financing Activities

Net  cash  used  in  financing  activities  amounted  to  $1.7  million  for  the  year  ended  December  31,  2018,  consisting  of  capital  withdraw  by  non-controlling
shareholder of $10.9 million, which was offset by cash received from short-term loans of $6.3 million and cash received from long-term loans of $2.9 million.

Net  cash  provided  by  financing  activities  amounted  to  $0.9  million  for  the  year  ended  December  31,  2017,  consisting  of  capital  contribution  from  non-
controlling interest holders of $0.9 million.

Net  cash  provided  by  financing  activities  amounted  to  $11.1  million  for  the  year  ended  December  31,  2016,  consisting  of  capital  contribution  from  non-
controlling interest of $9.8 million and proceeds received from stock option exercise of $1.3 million.

Intra-Company Transfers

Transfers of cash between our PRC operating subsidiaries and our non-PRC entities are regulated by certain PRC laws. For a description of these laws and the
effect  that  they  may  have  on  our  ability  to  meet  cash  obligations,  please  refer  to  “Item  3.  Key  Information  —  D.  Risk  Factors  —  Risks  Related  to  our
Business — Dividends payable to us by our wholly-owned operating subsidiaries may be subject to PRC withholding taxes, or we may be subject to PRC
taxation on our worldwide income, and dividends distributed to our investors may be subject to more PRC withholding taxes under PRC tax law,” “Item 3.
Key Information — D. Risk Factors — Risks Related to our Corporate Structure — We may rely principally on dividends and other distributions on equity
paid by our wholly-owned operating subsidiaries to fund any cash and financing requirements we may have, and any limitation on the ability of our operating
subsidiaries to pay dividends to us could have a material adverse effect on our ability to conduct our business,” “Item 3. Key Information — D. Risk Factors
—  Risks  Related  to  Doing  Business  in  China  —  Restrictions  on  currency  exchange  may  limit  our  ability  to  receive  and  use  our  revenues  or  financing
effectively,” “Item 3. Key Information — D. Risk Factors — Risks Related to Doing Business in China — PRC regulations relating to the establishment of
offshore special purpose companies by PRC residents and registration requirements for employee stock ownership plans or share option plans may subject our
PRC resident beneficial owners or the plan participants to personal liability, limit our ability to inject capital into our PRC subsidiaries, limit our subsidiaries’
ability  to  increase  their  registered  capital  or  distribute  profits  to  us,  or  may  otherwise  adversely  affect  us,”  “Item  4.  Information  on  the  Company  —  A.
History and Development of the Company — B. Business Overview — Regulation — Regulations on Dividend Distribution,” and “Item 4. Information on
the Company — A. History and Development of the Company — B. Business Overview — Regulation — SAFE Regulations on Offshore Investment by
PRC Residents and Employee Stock Options”. None of these regulations have had a material effect on our ability to meet our cash obligations.

62

 
 
 
 
  
 
 
 
 
 
 
 
 
C.

Research and Development, Patents and Licenses, Etc.

We have been developing certain technologies for broadcasting purposes. However, our financial commitment to development of these technologies has been
limited. During the past three years, we have not incurred a significant amount of research and development expense. While we are interested in and may
experiment with new technologies from time to time, we do not intend to materially increase our research and development spending in the foreseeable future.

D.

Trend Information

Other than as disclosed elsewhere in this annual report, we are not aware of any trends, uncertainties, demands, commitments or events that are reasonably
likely  to  have  a  material  effect  on  our  net  revenues,  income  from  continuing  operations,  profitability,  liquidity  or  capital  resources,  or  that  would  cause
reported financial information not necessarily to be indicative of future operating results or financial condition.

E.

Off-Balance Sheet Arrangements

We have not entered into any financial guarantees or other commitments to guarantee the payment obligations of any third parties. We have not entered into
any derivative contracts that are indexed to our shares and classified as shareholder’s equity, or that are not reflected in our consolidated financial statements.
Furthermore, we do not have any retained or contingent interest in assets transferred to an unconsolidated entity that serves as credit, liquidity or market risk
support to such entity. We do not have any variable interest in any unconsolidated entity that provides financing, liquidity, market risk or credit support to us
or engages in leasing, hedging or research and development services with us.

F.

Tabular Disclosure of Contractual Obligations

We  have  entered  into  operating  lease  agreements  primarily  for  our  office  spaces  in  China.  These  leases  expire  through  2021  and  are  renewable  upon
negotiation. In addition, the contract terms of our concession rights contracts are usually three to five years. Most of these concession rights expire through
2020 and are renewable upon negotiation. The following table sets forth our contractual obligations and commercial commitments as of December 31, 2018:

Payments Due by Period

Operating  lease agreements
Concession rights contracts
Total

G.

Safe Harbor

Total

  $

  $

2,339    $
24,946     
27,285    $

Less than 1
year

1-3 years
(in thousands of U.S. Dollars)
1,085    $
13,227     
14,312    $

1,254    $
11,719     
12,973    $

3-5 years

More than 5
years

-    $
-     
-    $

- 
- 
- 

See the section headed “Forward-Looking Information”.

ITEM 6.

DIRECTORS, SENIOR MANAGEMENT AND EMPLOYEES 

A.

Directors and Senior Management

The following table sets forth certain information regarding our directors and executive officers as of March 31, 2019. Mr. Richard Peidong Wu resigned as
our Chief Financial Officer effective in December 2018 for personal reasons, and Mr. Herman Man Guo was appointed to serve as the interim Chief Financial
Officer until February 28, 2019. Mr. Xin Li was appointed as our Chief Financial Officer effective in March 1, 2019. The resignation of Mr. Richard Peidong
Wu was not due to any disagreement with the management and the board of directors.

63

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
   
 
 
 
 
   
 
 
 
 
 
 
 
 
NAME

Herman Man Guo
Xin Li
Qing Xu
Conor Chiahung Yang
Shichong Shan
Dong Wen
Songzuo Xiang
Hua Zhuo
Hong Zhou
Peng Zhou
Rong Guo
Juntao Zhen

AGE
55
42
58
56
88
53
54
49
46
39
50
44

  Chairman, Chief Executive Officer and Director
  Chief Financial Officer
  Director and Executive President

POSITION

Independent Director
Independent Director
Independent Director
Independent Director
Independent Director
  Chief Operating Officer 
  Vice President
  Vice President 
  Vice President 

Mr. Herman Man Guo is our founder and has served as the chairman of our board of directors and our chief executive officer since our inception. Mr. Guo
served as our interim Chief Financial Officer in December 2018 to February 2019. He was the general manager of Beijing Sunshine Media Co., Ltd. from
1997 to 2004. From 1991 to 1996, Mr. Guo served as the deputy general manager of Beijing Trade & Technology Development Company. Prior to that, he
worked in China Civil Aviation Development Service Company from 1988 to 1990. Mr. Guo received his bachelor’s degree in applied mathematics from
People’s Liberation Army Information Engineering University in China in 1983 and an Executive MBA degree from Peking University in China in 2011.

Mr. Xin Li has served as our Chief Financial Officer since March 2019. Mr. Li Xin has extensive experience in the management of companies and connections
in the investment sector. Prior to joining us, Mr. Li was an assistant to president and the CFO of Grass Green Group, where he led several investment and
M&A projects, both domestically and internationally. Before joining Grass Green Group, Mr. Li was a managing director of CICFH Fund Management Co.,
Ltd.  (the  “CICFH”)  and  concurrently  served  as  CFO  of  the  fund’s  portfolio  company  in  2016  and  2017.  Prior  to  joining  CICFH,  Mr.  Li  held  senior
professional  positions  in  several  large  investment  institutions.  Mr.  Li  received  a  MBA  degree  from  Duke  University  in  2006  and  a  bachelor's  degree  in
international finance and accounting from Tsinghua University in 1999.

Mr. Qing Xu  has  served  as  our  director  since  our  inception  and  as  our  executive  president  since  June  2010.  From  October  2005  to  our  inception,  Mr.  Xu
served as a director of certain of our pre-existing affiliated entities. From 2003 to 2005, Mr. Xu served as a vice president of Zhongyuan Guoxin Investment
Guarantee Co., Ltd. Prior to that, he served as a department director of China Haohua Group Co., Ltd. from 1997 to 2003 and as a department manager of
Beijing Trade & Technology Development Company from 1991 to 1997. Mr. Xu was a secretary at the PRC State Council Secretary Bureau from 1984 to
1991. Mr. Xu received his associate’s degree in business and economics management from Beijing Normal University in 1996.

Mr.  Conor  Chiahung  Yang  has  served  as  our  independent  director  since  March  2013.  Mr.  Yang  is  the  president  and  cofounder  of  Black  Fish  Group.
Previously, Mr. Yang was the chief financial officer of Tuniu Corporation from January 2013 to November 2017. Mr. Yang was the chief financial officer of
E-Commerce China Dangdang Inc. from March 2010 to July 2012 and the chief financial officer of our company, from March 2007 to March 2010. Mr. Yang
was the chief executive officer of Rock Mobile Corporation from 2004 to February 2007. From 1999 to 2004, Mr. Yang served as the chief financial officer of
the Asia Pacific region for CellStar Asia Corporation. Mr. Yang was an executive director of Goldman Sachs (Asia) L.L.C. from 1997 to 1999. Prior to that,
Mr. Yang was a vice president of Lehman Brothers Asia Limited from 1994 to 1996 and an associate at Morgan Stanley Asia Limited from 1992 to 1994. Mr.
Yang currently serves as an independent director of China Online Education Group. Mr. Yang received his MBA degree from University of California, Los
Angeles in 1992 and his bachelor’s degree from Fu Jen University in Taiwan in 1985. .

Mr. Shichong Shan has served as our independent director since July 2007. Mr. Shan has retired since 1996. Before he retired, Mr. Shan had held a number of
senior executive positions in various government agencies and other organizations in the aviation industry in China, including the General Administration of
Civil Aviation of China. Mr. Shan graduated from Shanghai Lixin University of Commerce and attended the college program at the Eastern China Military
and Politics Institute.

64

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Mr. Dong Wen has served as our independent director since July 2015. Mr. Wen has been the general manager of the home furnishing business division of
Leju Holdings Limited (NYSE: LEJU) since 2011. Prior to that, he worked for four years as the chief executive officer of Lianlian Technology Group, which
is the largest channel management vendor for authorized third-party prepayment for China Mobile subscribers according to that company. From 2002 to 2007,
Mr. Wen worked as a senior vice president of B&Q China.

Dr. Songzuo Xiang has served as our independent director since November 2008. He currently serves on the board of China Digital TV Co. Ltd., an NYSE-
listed  company  providing  conditional  access  systems  to  China’s  digital  television  market.  From  March  2009  to  October  2009  and  from  July  2000  to  July
2009, Dr. Xiang served as chief executive officer and director, respectively, of Ku6 Media Co., Ltd., a Nasdaq-listed company. He previously served as the
Deputy Director of the Fund Planning Department at the People’s Bank of China Shenzhen Branch and was an investment manager at Shenzhen Resources &
Property Development Group. He was a visiting scholar at Columbia University from May 1999 to July 2000 and at Cambridge University from October
1998 to May 1999. Dr. Xiang received his bachelor’s degree in engineering in Huazhong University of Science and Technology in 1986, his master’s degree
in international affairs from Columbia University in 1999, his master’s degree in management science in 1993 and his Ph.D. degree in economics in 1993
from Renmin University in China.

Mr. Hua Zhuo. Mr. Zhuo has served as our independent director since July 2015. He has worked as the chairman and president of Zhongyuan Guoxin Credit
Financing Guarantee Co., Ltd. since 2003. Prior to that, he worked as the general manager at several other companies. Mr. Zhuo received his MBA degree
from Peking University.

Mr. Hong Zhou has served as our Chief Operating Officer since May 2018. Previously, Mr. Zhou served as the head of a large-scale production and scientific
consortium  of  China  Aerospace  Science  and  Technology  Group.  Prior  to  that,  Mr.  Zhou  served  as  deputy  chief  engineer  and  senior  project  director  of
enterprise  development  department  under  aviation  airborne  communication  division  of  China  Satcom  Group.  Mr.  Zhou  received  a  Doctor  of  Engineering
degree from the school of aeronautical science and engineering, Beihang Universtiy.

Mr. Peng  Zhou  has  served  as  our  vice  president  in  charge  of  marketing  and  public  relationship  since  January  2016.  Mr.  Peng  Zhou  has  had  an  intimate
knowledge in marketing and strategic planning for online products. Previously, Mr. Zhou served as the senior vice president of Tianji.com from January 2015
to November 2015. From January 2012 to December 2014, Mr. Zhou was the senior director of industry analysis in the marketing consultant department of
Baidu.com. From August 2007 to August 2011, Mr. Zhou served as the marketing director of baicheng.com. Prior to that, Mr. Zhou worked in elong.com and
Sohu.com. Mr. Zhou received his bachelor’s degree from Tianjin University of Commerce.

Ms. Rong Guo has served as our vice president in charge of In-train Wi-Fi business since early 2015. Prior joining us, Ms. Guo has accumulated an abundant
management experience on the online media industry. Ms. Guo served as the as the vice general manager of Baiyun International Airport Advertising Co.,
Ltd. and the account director of Shanghai Shengshi Great Wall Advertising Co., Ltd.

Mr. Juntao Zhen has served as our vice president and the general manager of Wi-Fi business since 2017. Prior joining us, Mr. Zhen served as the as the chief
architect  and  chief  architect  team  leader  of  NOKIA  Beijing  research  and  development  center,  he  was  responsible  for  the  system  architecture  of  mobile
communication equipment, software and hardware technology development and team management in NOKIA Beijing research and development center.

No  family  relationship  exists  between  any  of  our  directors  and  executive  officers.  There  are  no  arrangements  or  understandings  with  major  shareholders,
customers, suppliers or others pursuant to which any person referred to above was selected as a director or member of senior management.

Employment Agreements 

We have entered into employment agreements with Herman Man Guo and Xin Li. Our employment agreements with Mr. Guo has an unfixed duration as
required  by  the  PRC  Employment  Law.  Mr.  Guo  may  terminate  the  respective  agreement  with  a  one-month  prior  notice  while  we  will  only  be  able  to
terminate such agreement in limited circumstances, such as for cause. Our employment agreement with Mr. Xin Li has a fixed duration until February, 2022
 and  can  be  terminated  by  either  us  or  Mr.  Xin  Li  with  a  one-month  prior  notice  over  the  term  of  the  duration.  We  have  also  entered  into  employment
agreements with our other executive officers. Each of the contract terms was a period of two or three years. We may terminate the employment for cause, at
any  time,  without  notice  or  remuneration,  for  certain  acts  of  the  employee,  including  but  not  limited  to  a  conviction  or  plea  of  guilty  to  certain  crimes,
negligence or dishonesty to our detriment and failure to perform the agreed-to duties after a reasonable opportunity to cure the failure. Furthermore, either we
or an executive officer may terminate the employment at any time without cause upon advance written notice to the other party. These agreements do not
provide for any special termination benefits, nor do we have other arrangements with these executive officers for special termination benefits.

65

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Each executive officer has agreed to hold, both during and after the employment agreement expires or is earlier terminated, in strict confidence and not to use,
except  as  required  in  the  performance  of  his  duties  in  connection  with  the  employment,  any  confidential  information,  trade  secrets  and  know-how  of  our
company or the confidential information of any third party, including our VIEs and our subsidiaries, received by us. In addition, each executive officer has
agreed to be bound by non-competition restrictions set forth in his or her employment agreement. Specifically, each executive officer has agreed not to, for a
period ranging from one to two years following the termination or expiration of the employment agreement, (i) carry on or be engaged or interested, directly
or indirectly, as shareholder, director, employee, partner, agent or otherwise carry on any business in direct competition with our business; (ii) solicit or entice
away from us, or attempt to solicit or entice away from us, any person or entity who has been our customer, client or our representative or agent or in the habit
of dealing with us within two years prior to such executive officer’s termination of employment; (iii) solicit or entice away from us, or attempt to solicit or
entice  away  from  us,  any  person  or  entity  who  has  been  our  officer,  manager,  consultant  or  employee  within  two  years  prior  to  such  executive  officer’s
termination  of  employment;  or  (iv)  use  a  name  including  the  word  “AirMedia”  or  any  other  words  used  by  us  in  our  name  or  in  the  name  of  any  of  our
products or services, in such a way as to be capable of or likely to be confused with our name or the name of our products or services.

B.

Compensation

In 2018, the aggregate cash compensation to our executive officers was approximately $0.5 million and the aggregate cash compensation to our non-executive
directors was approximately $0.2 million. Our PRC subsidiaries and consolidated VIEs are required by law to make contributions equal to certain percentages
of  each  employee’s  salary  for  his  or  her  pension  insurance,  medical  insurance,  housing  fund,  unemployment  and  other  statutory  benefits.  Other  than  the
above-mentioned pension insurance mandated by applicable PRC law, we have not set aside or accrued any amount to provide pension, retirement or other
similar benefits to our executive officers and directors. No executive officer is entitled to any severance benefits upon termination of his or her employment
with our company except as required under applicable PRC law. 

Share Options

In July 2007, we adopted the 2007 Option Plan to attract and retain the best available personnel, provide additional incentives to employees, directors and
consultants, and promote the success of our business. In December 2009, we amended the 2007 Option Plan by increasing the maximum aggregate number of
shares issuable under the plan from 12,000,000 to 17,000,000. In March 2011, our board of directors authorized the issuance of 2,000,000 ordinary shares
under the 2011 Option Plan with the same aim as the 2007 Option Plan. In 2012, our board of directors adopted the 2012 Option Plan, under which we are
authorized to grant restricted shares or options and other awards for a total issuance of up to 6,000,000 ordinary shares. As of December 31, 2018, options to
purchase 5,857,755 of our ordinary shares were outstanding. The majority of these options will vest on a straight-line basis over a three-year period, with one-
twelfth of the options vesting each quarter from the date of grant.

The following table summarizes, as of December 31, 2018, the outstanding options granted to our executive officers, directors and
to other individuals as a group under our 2007 Option Plan, as amended, 2011 Option Plan and 2012 Option Plan.   

66

 
 
 
 
 
 
 
 
 
 
Name

Herman Man Guo
Richard Peidong Wu
Xin Li
Qing Xu
Conor Chia-hung Yang
Conor Chia-hung Yang
Conor Chia-hung Yang
Shichong Shan
Dong Wen
Songzuo Xiang
Hua Zhuo
Peng Zhou
Rong Guo
Juntao Zhen
Other individuals as a group
Other individuals as a group
Other individuals as a group
Other individuals as a group

Ordinary
Shares
Underlying
Options

1,000,000     
1,276,620     
—     
 *     
*     
*     
*     
*     
—     
*     
—     
—     
—     
—     
600,000     
200,000     
180,000     
40,000     

Exercise
Price
($/Share)(1)    
1.15   
1.025   
N/A   
1.15   
1.15   
1.15   
1.15   
1.15   
N/A   
1.15   
N/A   
N/A   
N/A   
N/A   
1.15   
1.025   
1.675   
1.045   

Date of Grant
July 2, 2007
June 1, 2014
N/A
March 22, 2011
July 2, 2007
November 29, 2007
July 10, 2009
July 20, 2007
N/A
July 10, 2009
N/A
N/A
N/A
N/A
March 22, 2011
June 1, 2014
May 12, 2015
August 1, 2014

Expiration Date
December 31, 2019
December 31, 2019
N/A
March 23, 2021
December 31, 2019
December 31, 2019
December 31, 2019
December 31, 2019
N/A
December 31, 2019
N/A
N/A
N/A
N/A
March 22, 2021
June 1, 2019
May 12, 2020
August 1, 2019

* Aggregate beneficial ownership of our company by such officer or director is less than 1% of our total outstanding ordinary shares.

(1) On  August  23,  2011,  in  order  to  provide  better  incentive  to  our  employees,  our  board  of  directors  approved  an  adjustment  to  the  exercise  price  of  a
portion of the stock options previously granted to certain optionees on July 2, 2007, July 20, 2007, November 29, 2007, July 10, 2009 and March 22,
2011. The exercise price for the adjusted portion of the options is $1.15 per ordinary share and the exercise price for the unadjusted portion will remain
the same at $1.57 per ordinary share.

The following paragraphs summarize the terms of our 2007 Option Plan, as amended, 2011 Option Plan and 2012 Option Plan:

Plan Administration. Our board of directors, or a committee designated by our board or directors, will administer the plans. The committee or the full board
of directors, as appropriate, will determine the provisions and terms and conditions of each option grant.

Award Agreements. Options and stock purchase rights granted under our plans are evidenced by a stock option agreement or a stock purchase right agreement,
as  applicable,  that  sets  forth  the  terms,  conditions  and  limitations  for  each  grant.  In  addition,  the  stock  option  agreement  and  the  stock  purchase  right
agreement also provide that securities granted are subject to a 180-day lock-up period following the effective date of a registration statement filed by us under
the Securities Act, if so requested by us or any representative of the underwriters in connection with any registration of the offering of any of our securities.

67

 
 
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
 
 
 
 
 
 
 
 
 
Eligibility. We may grant awards to our employees, directors and consultants or any of our related entities, which include our subsidiaries or any entities in
which we hold a substantial ownership interest.

Acceleration  of  Options  upon  Corporate  Transactions.  The  outstanding  options  will  terminate  and  accelerate  upon  occurrence  of  a  change-of-control
corporate transaction where the successor entity does not assume our outstanding options under the plans. In such event, each outstanding option will become
fully vested and immediately exercisable, and the transfer restrictions on the awards will be released and the repurchase or forfeiture rights will terminate
immediately before the date of the change-of-control transaction provided that the grantee’s continuous service with us shall not be terminated before that
date.

Exercise  Price  and  Terms  of  the  Options. The  exercise  price  per  share  subject  to  an  option  may  be  amended  or  adjusted  in  the  absolute  discretion  of  the
compensation committee, the determination of which shall be final, binding and conclusive. To the extent not prohibited by applicable laws or exchange rules,
a  re-pricing  of  options  mentioned  in  the  preceding  sentence  shall  be  effective  without  the  approval  of  our  shareholders  or  the  approval  of  the  optionees.
Notwithstanding the foregoing, the exercise price per share subject to an option may not be increased without the approval of the affected optionees. If we
grant an option to an individual who, at the date of grant, possesses more than ten percent of the total combined voting power of all classes of our shares, the
exercise price cannot be less than 110% of the fair market value of our ordinary shares on the date of that grant. The compensation committee shall determine
the time or times at which an option may be exercised in whole or in part, including exercise prior to vesting, and shall determine any conditions, if any, that
must be satisfied before all or part of an option may be exercised. The term of each option grant shall be stated in the stock option agreement, provided that
the term shall not exceed 10 years from the date of the grant.

Vesting Schedule. In general, the plan administrator determines, or the stock option agreement specifies, the vesting schedule.

Transfer  Restrictions.  Options  to  purchase  our  ordinary  shares  may  not  be  transferred  in  any  manner  by  the  optionee  other  than  by  will  or  the  laws  of
succession and may be exercised during the lifetime of the optionee only by the optionee.

Termination of the Plan. Unless terminated earlier, the 2007 Option Plan will expire and no further awards may be granted under it after July 2017, our 2011
Option Plan will expire and no further awards may be granted under it after March 2021, and our 2012 Option Plan will expire and no further awards may be
granted under it after November 2022. Our board of directors has the authority to amend or terminate the plan subject to shareholder approval to the extent
necessary to comply with applicable law. However, no such action may impair the rights of any optionee unless agreed by the optionee.

C.

Board Practices

Our board of directors currently consists of seven directors. A director is not required to hold any shares in our company by way of qualification. A director
may vote with respect to any contract, proposed contract or arrangement in which he is materially interested. A director may exercise all the powers of our
company to borrow money, mortgage its undertaking, property and uncalled capital, and issue debentures or other securities whenever money is borrowed or
as security for any obligation of our company or of any third party. The remuneration to be paid to the directors is determined by the board of directors. There
is no age limit requirement for directors.

Board Committees  

We  have  established  three  committees  under  the  board  of  directors:  an  audit  committee,  a  compensation  committee,  and  a  compliance  committee.  We
currently do not plan to establish a nominating committee. The independent directors of our company will select and recommend to the board for nomination
by the board such candidates as the independent directors, in the exercise of their judgment, have found to be well qualified and willing and available to serve
as our directors prior to each annual meeting of our shareholders at which our directors are to be elected or reelected. In addition, our board of directors has
resolved that director nominations be approved by a majority of the board as well as a majority of the independent directors of the board. A majority of our
board of directors are independent directors. We have adopted a charter for each of the board committees. Each committee’s members and responsibilities are
described below.

68

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Audit Committee.  Our  audit  committee  consists  of  Messrs.  Songzuo  Xiang,  Shichong  Shan  and  Conor  Chia-hung  Yang.  Mr.  Yang  is  the  chairperson.  Our
board  of  directors  has  determined  that  all  members  of  our  audit  committee  satisfy  the  “independence”  requirements  of  Rule  10A-3  under  the  Securities
Exchange Act of 1934, as amended, or the Exchange Act, and the rules and regulations of the Nasdaq Stock Market LLC. We have determined that each of
Songzuo Xiang and Conor Chia-hung Yang qualifies as an “audit committee financial expert.” The audit committee oversees our accounting and financial
reporting processes and the audits of the financial statements of our company. The audit committee is responsible for, among other things:

·

·

·

·

·

·

·

selecting the independent auditors and pre-approving all auditing and non-auditing services permitted to be performed by the independent auditors;  

reviewing with the independent auditors any audit problems or difficulties and management’s response;  

reviewing and approving all proposed related-party transactions on an ongoing basis;  

discussing the annual audited financial statements with management and the independent auditors;  

reviewing major issues as to the adequacy of our internal controls and any special audit steps adopted in light of material control deficiencies;  

annually reviewing and reassessing the adequacy of our audit committee charter;  

other matters specifically delegated to our audit committee by our board of directors from time to time;  

· meeting separately and periodically with management and the independent auditors; and 

·

reporting regularly to the full board of directors.  

Compensation Committee. Our compensation committee consists of Messrs. Hua Zhuo, Conor Chia-hung Yang and Shichong Shan. Conor Chia-hung Yang is
the  chairperson.  Our  board  of  directors  has  determined  that  Messrs.  Hua  Zhuo,  Conor  Chia-hung  Yang  and  Shichong  Shan  satisfy  the  “independence”
requirements of the rules and regulations of the Nasdaq Stock Market LLC. Our compensation committee assists the board in reviewing and approving the
compensation structure of our directors and executive officers, including all forms of compensation to be provided to our directors and executive officers. Our
chief  executive  officer  may  not  be  present  at  any  committee  meeting  during  which  his  compensation  is  deliberated.  The  compensation  committee  is
responsible for, among other things:

·

·

·

reviewing and recommending to the board with respect to the total compensation package for our executive officers;  

reviewing and making recommendations to the board with respect to the compensation of our directors; and 

reviewing  periodically  and  approving  any  long-term  incentive  compensation  or  equity  plans,  programs  or  similar  arrangements,  annual  bonuses,
employee pension and welfare benefit plans.  

Compliance Committee. Our compliance committee consists of Messrs. Qing Xu, Songzuo Xiang and Hua Zhuo. Mr. Xu is the chairperson. Our compliance
committee assists the board in overseeing the Company’s compliance with the laws and regulations applicable to the Company’s business, and compliance
with  the  Company’s  code  of  business  conduct  and  ethics  and  related  policies  by  employees,  officers,  directors  and  other  agents  and  associates  of  the
Company. The compliance committee is responsible for, among other things:

·

·

establishing and revising project and purchase control policies;  

establishing and revising administration and business supervision policies;  

69

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
·

·

accepting, investigating, and settling any comments, complaints, and reports from employees;  

investigating and settling any matters delegated from the board of directors; and 

· monitoring the status of implementation of company policies.  

Duties of Directors

Under Cayman Islands law, our directors owe fiduciary duties to our company, including a duty to act honestly, and a duty to act in what they consider in
good faith to be in our best interests. Our directors must also exercise their powers only for a proper purpose. Our directors also owe to our company a duty to
act with skills they actually possess and exercise such care and diligence that a reasonably prudent person would exercise in comparable circumstances. It was
previously considered that a director need not exhibit in the performance of his duties a greater degree of skill than may reasonably be expected from a person
of his knowledge and experience. However, English and Commonwealth courts have moved towards an objective standard with regard to the required skill
and  care  and  these  authorities  are  likely  to  be  followed  in  the  Cayman  Islands.  In  fulfilling  their  duty  of  care  to  our  company,  our  directors  must  ensure
compliance  with  our  amended  and  restated  memorandum  and  articles  of  association,  as  amended  and  restated  from  time  to  time,  and  the  rights  vested
thereunder in the holders of the shares. Our directors owe their fiduciary duties to our company and not to our company’s individual shareholders, and it is our
company which has the right to seek damages if a duty owed by our directors is breached. In limited exceptional circumstances, a shareholder may have the
right to seek damages in our name if a duty owed by our directors is breached.

Terms of Directors and Officers

All directors hold office until the expiration of their terms and until their successors have been elected and qualified. A director may be removed from office
before the expiry of his term by a special resolution passed by the shareholders. The directors shall be subject to retirement by rotation. Any director shall
serve a term of office which shall expire on the 31st day of July which is not less than one year nor more than two years after the date of his appointment.
Upon the expiry of each director’s term of office, he shall automatically retire and cease to be a director, but shall be eligible for re-election by the board of
directors. Any director who is so re-elected shall serve an additional term which shall expire on the 31st day of July of the year which is two years after such
re-election. There shall be no limit on the number of times which a director may be re-elected or the number of additional terms which any such director may
serve.  Every  director  is  subject  to  retirement  in  accordance  with  our  articles  of  association  at  least  once  every  two  years.  Our  articles  of  association  also
provide  that  the  office  of  a  director  shall  be  vacated  in  a  limited  number  of  circumstances,  namely  if  the  director:  (a)  becomes  bankrupt  or  makes  any
arrangement or composition with his creditors; (b) is found to be or becomes of unsound mind; (c) resigns his office by notice in writing to our Company; or
(d) without special leave of absence from the board of directors, is absent from meetings of the board of directors for six consecutive months and the board of
directors resolves that his office be vacated. Officers are elected by and serve at the discretion of our board of directors.

In addition, our service agreements with our directors do not provide benefits upon termination of their services.

D.       Employees 

We had 1,052, 845 and 315 employees as of December 31, 2016, 2017, and 2018 respectively. The following table sets forth the number of our employees by
area of business as of December 31, 2016, 2017 and 2018, respectively:

Sales and Marketing Department
Quality Control and Technology Department
Programming Department
Resources Development Department
General Administrative and Accounting
Total

2016

As of December 31,
2017

Number of 
Employees     % of Total

Number of 
Employees     % of Total    

387     
317     
124     
15     
209     
1,052     

36.8     
30.1     
11.8     
1.4     
19.9     
100.0     

242     
253     
129     
13     
208     
845     

28.6     
29.9     
15.4     
1.5     
24.6     
100.0     

2018

Number of 
Employees     % of Total  
18.7 
27.0 
26.7 
0.6 
27.0 
100.0 

59     
85     
84     
2     
85     
315     

70

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
   
   
   
   
   
   
   
 
 
 
The following table sets forth the breakdown of employees by geographic location as of December 31, 2018:

City

Beijing
Guangzhou
Shenyang
Others
Total

Number of
Employees

% of Total

218     
31     
45     
21     
315     

69.2 
9.8 
14.3 
6.7 
100.0 

Generally we enter into standard employment contracts with our officers, managers and other employees. According to these contracts, all of our employees
are prohibited from engaging in any other employment during the period of their employment with us. The employment contracts with officers and managers
are subject to renewal every three years and the employment contracts with other employees are subject to renewal every year.

In addition, we enter into standard confidentiality agreements with all of our employees including officers and managers that prohibit any employee from
disclosing confidential information obtained during their employment with us. Furthermore, the confidentiality agreements include a covenant that prohibits
all employees from engaging in any activities that compete with our business up to two years after their employment with us terminates.

Our employees are not covered by any collective bargaining agreement. We consider our relations with our employees to be generally good.

E.

Share Ownership

The following table sets forth information with respect to the beneficial ownership of our ordinary shares as of March 31, 2019, by:

·

·

each of our directors and executive officers; and

each principal shareholder, or person known to us to own beneficially more than 5.0% of our ordinary shares.

The calculations in the shareholder table below are based on 125,664,777 ordinary shares outstanding as of March 31, 2019 (excluding 2,032,278 ordinary
shares and ordinary shares represented by ADSs reserved for settlement upon exercise of our incentive share awards). Beneficial ownership is determined in
accordance with the rules and regulations of the SEC. In computing the number of shares beneficially owned by a person and the percentage ownership of
that person, we have included shares that the person has the right to acquire within  60 days after March 31, 2019, the most recent practicable date, including
through the exercise of any option, or other right or the conversion of any other security. These shares, however, are not included in the computation of the
percentage ownership of any other person.

71

 
 
 
 
   
 
   
   
   
   
   
 
 
 
 
 
 
 
 
 
 
 
Directors and Executive Officers:
Herman Man Guo(1)
Xin Li
Qing Xu(2)
Conor Chiahung Yang(3)
Shichong Shan
Dong Wen
Songzuo Xiang
Hua Zhuo
Hong Zhou
Peng Zhou
Rong Guo
Juntao Zhen
All directors and executive officers
Principal Shareholders:
Dan Shao (4)
Wealthy Environment Limited(5)
Bison Capital Media Limited (6)

Shares Beneficially Owned
%

Number

20,510,980     
—     
1,950,000     
1,348,913     
*     
—     
*     
—     
*     
*     
—     
—     
24,018,226     

20,584,214     
17,505,980     
12,000,000     

16.2 
— 
1.5 
1.1 
* 
— 
* 
— 
* 
* 
— 
— 
18.8 

16.1 
13.7 
9.4 

* Aggregate beneficial ownership of our company by such director or officer is less than 1% of our total outstanding ordinary shares.

** The business address of our directors and executive officers is 15/F, Sky Plaza, No. 46 Dongzhimenwai Street, Dongcheng District, Beijing 100027, The

People’s Republic of China.

(1) Includes (i) 16,105,980 ordinary shares held by Wealthy Environment Limited, a BVI company wholly owned by Mr. Herman Man Guo, (ii) 1,400,000
ordinary  shares  represented  by  American  Depositary  Shares  held  by  Wealthy  Environment  Limited,  (iii)  2,000,000  ordinary  shares  represented  by
American Depositary Shares held by Mr. Herman Man Guo, and (iv) 1,005,000 ordinary shares issuable upon exercise of options held by Mr. Guo that
are exercisable within 60 days.  

(2) Includes  (i)  1,000,000  ordinary  shares  held  by  Mambo  Fiesta  Limited,  a  BVI  company  wholly  owned  by  Mr.  Qing  Xu,  (ii)  600,000  ordinary  shares
represented by American Depositary Shares held by Mr. Qing Xu, and (iii) 350,000 ordinary shares issuable upon exercise of options held by Mr. Xu that
are exercisable within 60 days.  

(3) Includes (i) 965,942 ordinary shares represented by American Depositary Shares, and (ii) 382,971 ordinary shares issuable upon exercise of options held

by Mr. Conor Chiahung Yang that are exercisable within 60 days.  

(4) Includes (i) 20,000,000 ordinary shares held by Global Earning Pacific Limited and (ii) 584,214 ordinary shares represented by ADSs that Ms. Dan Shao
purchased in one or more open-market transactions. Global Earning Pacific Limited, a company incorporated in BVI, is wholly owned and controlled by
Ms. Dan Shao, Mr. Herman Man Guo’s wife. The registered address of Global Earning Pacific Limited is OMC Chambers, Wickham Cay 1, Road Town
Tortola, BVI.  

(5) Includes (i) 16,105,980 ordinary shares held by Wealthy Environment Limited, and (ii) 1,400,000 ordinary shares represented by American Depositary
Shares  held  by  Wealthy  Environment  Limited.  Wealthy  Environment  Limited,  a  company  incorporated  in  BVI,  is  wholly  owned  and  controlled  by
Herman Man Guo. The registered address of Wealthy Environment Limited is P.O. Box 173, Kingston Chambers, Road Town Tortola, BVI.  

(6) The  address  of  Bison  Capital  Media  Limited  is  c/o  Bison  Capital  Holding  Company  Limited,  609-610,  21st  Century  Tower,  40  Liangmaqiao  Road,
Chaoyang District, Beijing, People’s Republic of China, 100016. Bison Capital Media Limited, a Cayman Islands company, is wholly-owned by Bison
Capital Holding Company Limited, a Cayman Islands company, which is in turn wholly owned by Ms. Fengyun Jiang, a citizen of Hong Kong Special
Administrative  Region.  Ms.  Jiang  is  the  sole  director  of  both  Bison  Capital  Media  Limited  and  Bison  Capital  Holding  Company  Limited.  Ms.  Jiang
possesses the power to direct the voting and disposition of the shares owned by Bison Capital Media Limited and may be deemed to have beneficial
ownership of such shares.

72

 
 
 
 
 
 
 
   
 
   
      
  
   
   
   
   
   
   
   
   
   
   
   
   
   
   
      
  
   
   
   
 
 
 
 
 
 
 
 
 
 
 
 
Other than as otherwise disclosed in this report, we are not directly or indirectly owned or controlled by another corporation, by any foreign government or by
any other natural or legal person severally or jointly. None of our major shareholders have different voting rights from other shareholders. We are not aware of
any arrangement that may, at a subsequent date, result in a change of control of our company.

As of March 31, 2019, 127,697,055 of our ordinary shares were issued and outstanding, of which 2,032,278 ordinary shares are issued to our depositary bank
reserved for future exercise of vested options. To our knowledge, we had only one record shareholder in the United States, JPMorgan Chase Bank, N. A.,
which  is  the  depositary  of  our  ADS  program  and  held  approximately  71%  of  our  total  outstanding  ordinary  shares  as  of  March  31,  2019. The  number  of
beneficial owners of our ADSs in the United States is likely to be much larger than the number of record holders of our ordinary shares in the United States.

For the options granted to our directors, officers and employees, please refer to “— B. Compensation — Share Options.”

ITEM 7.

MAJOR SHAREHOLDERS AND RELATED PARTY TRANSACTIONS 

A.

Major Shareholders

Please refer to “Item 6. Directors, Senior Management and Employees — E. Share Ownership.”

B.

Related Party Transactions

Contractual Arrangements

Our consolidated VIEs, Beijing Yuehang, and Linghang Shengshi, together with their subsidiaries, directly operate our air travel advertising network, enter
into related concession rights contracts and sell advertising time slots and advertising locations to our advertisers. Our consolidated VIE, AM Online, along
with  its  subsidiaries,  enters  into  concession  rights  contracts  in  relation  to  our  Wi-Fi  business  and  is  directly  operate  this  business  and  enter  into  related
business  contracts.  We  have  been  and  expect  to  continue  to  be  dependent  on  our  VIEs  to  operate  our  advertising  business  and  Wi-Fi  business.  Chuangyi
Technology has entered into contractual arrangements with our VIEs, pursuant to which Chuangyi Technology provides exclusive technology support and
service and technology development services in exchange for payments from them. In addition, Chuangyi Technology has entered into agreements with our
VIEs and each of their individual shareholders (except Yi Zhang), which provide Chuangyi Technology with the substantial ability to control our VIEs. These
agreements are summarized in the following paragraphs.

73

 
 
 
 
 
 
 
 
 
 
 
 
 
·

·

·

Technology support and service agreements: Chuangyi Technology provides exclusive technology support and consulting services to our VIEs and
in  return,  the  VIEs  are  required  to  pay  Chuangyi  Technology  service  fees.  Except  for  AM  Online,  the  VIEs  pay  to  Chuangyi  Technology  annual
service fees in the amount that guarantee that the VIEs can achieve, after deducting such service fees payable to Chuangyi Technology, a net cost-
plus rate of no less than 0.5% in the case of Linghang Shengshi and Jiaming Advertising, or 1.0% in the case of Beijing Yuehang. It is at Chuangyi
Technology’s sole discretion that the rate and amount of service fees ultimately charged the VIEs under these agreements are determined. The “net
cost-plus rate” refers to the operating profit as a percentage of total costs and expenses of a certain entity. The technology support and service fees
for  each  given  year  payable  by  AM  Online  to  Chuangyi  Technology  under  AM  Online’s  technology  support  and  service  agreement  shall  be
determined by AM Online and Chuangyi Technology at the first month of such year taking into account several factors. Those factors include the
credential  of  the  team  of  Chuangyi  Technology  that  provides  services  to  AM  Online,  the  number  of  service  hours,  the  nature  and  value  of  the
services provided by Chuangyi Technology, the extent to which Chuangyi Technology provides patent or other license to AM Online in its provision
of technology support and service and the correlation between AM Online’s results of operations and the technology support and service provided by
Chuangyi Technology. In the event Chuangyi Technology finds it necessary to make subsequent adjustment to the amount of fees, AM Online shall
negotiate in good faith with Chuangyi Technology to determine the new fee. The technology support and service agreements are effective for ten
years and such term is automatically renewed upon their expiration unless either party to an agreement informs the other party of its intention not to
extend at least twenty days prior to the expiration of these agreements.

Technology development agreements: Our VIEs exclusively engage Chuangyi Technology to provide technology development services. Chuangyi
Technology  owns  the  intellectual  property  rights  developed  in  the  performance  of  these  agreements.  Except  for  AM  Online,  the  VIEs  pay  to
Chuangyi  Technology  annual  service  fees  in  the  amount  that  guarantee  that  the  VIEs  can  achieve,  after  deducting  such  service  fees  payable  to
Chuangyi Technology, a net cost-plus rate of no less than 0.5% in the case of Linghang Shengshi and Jiaming Advertising, which final rate should be
determined by Chuangyi Technology. It is at Chuangyi Technology’s sole discretion the rate and amount of fees ultimately charged the VIEs under
these agreements are determined. The “net cost-plus rate” refers to the operating profit as a percentage of total costs and expenses of a certain entity.
The technology development fees for each given year payable by AM Online to Chuangyi Technology under AM Online’s technology development
agreement shall be determined by AM Online and Chuangyi Technology at the first month of such year taking into account several factors. Those
factors include the credential of the team of Chuangyi Technology that provides services to AM Online, the number of service hours, the nature and
value of the services provided by Chuangyi Technology, the extent to which Chuangyi Technology provides patent or other license to AM Online in
its  provision  of  technology  development  service  and  the  correlation  between  AM  Online’s  results  of  operations  and  the  technology  development
service provided by Chuangyi Technology. In the event Chuangyi Technology finds it necessary to make subsequent adjustment to the amount of
fees, AM Online shall negotiate in good faith with Chuangyi Technology to determine the new fee. The technology development agreements are
effective for ten years and such term is automatically renewed upon their expiration unless either party informs the other party of its intention not to
extend at least twenty days prior to the expiration of these agreements.

Exclusive technology consultation and service agreement: AM online exclusively engages Chuangyi Technology to provide consultation services
in relation to management, training, marketing and promotion. AM Online agrees to pay to Chuangyi Technology the amount of annual service fees
as determined by Chuangyi Technology. In the event Chuangyi Technology finds it necessary to make subsequent adjustment to the amount of fees,
AM Online shall negotiate in good faith with Chuangyi Technology to determine the new fees. The exclusive technology consultation and service
agreement remains effective for ten years and such term may be reviewed by Chuangyi Technology’s written confirmation prior to the expiration of
the agreement term. 

74

 
 
 
 
 
 
 
·

·

·

Call  option  agreements:  Under  the  call  option  agreements  between  Chuangyi  Technology  and  the  individual  shareholders  (except  Yi  Zhang)  of
Linghang  Shengshi,  Beijing  Yuehang  and  Jiaming  Advertising,  the  shareholders  of  those  VIEs  irrevocably  granted  Chuangyi  Technology  or  its
designated third party an exclusive option to purchase from the VIEs’ shareholders, to the extent permitted under PRC law, all the equity interests in
the VIEs, as the case may be, for the minimum amount of consideration permitted by the applicable law without any other conditions. Under the call
option agreements between Chuangyi Technology and the shareholders of AM Online, the shareholders of AM Online (except Yi Zhang) irrevocably
granted  Chuangyi  Technology  or  its  designated  third  party  an  exclusive  option  to  purchase  from  the  shareholders  of  AM  Online,  to  the  extent
permitted  under  PRC  law,  all  the  equity  interests  in  AM  Online,  as  the  case  may  be.  To  the  extent  the  applicable  PRC  law  does  not  require  the
valuation of the subject equity interests and does not otherwise restrict the purchase price for such equity interests, such purchase price shall equal
the amount of actual payment made by the respective shareholders of AM Online with respect to the equity interests whether in the form or share
capital injection or secondary purchase price. If and where the applicable PRC law requires the valuation of the subject equity interests or otherwise
has restrictions on the purchase price for such equity interests, such purchase price shall equal the minimum amount of consideration permitted by
the applicable law. In addition, under these agreements (except for the call option agreements between Chuangyi Technology and the shareholders of
AM Online), Chuangyi Technology has undertaken to act as guarantor of VIEs in all operations-related contracts, agreements and transactions and
commit to provide loans to support the business development needs of VIEs or if the VIEs suffer operating difficulties, provided that the relevant
VIE’s shareholders satisfy the terms and conditions in the call option agreements. Under PRC laws, to provide an effective guarantee, a guarantor
needs  to  execute  a  specific  written  agreement  with  the  beneficiary  of  the  guarantee.  As  Chuangyi  Technology  has  not  entered  into  any  written
guarantee agreements with any third party beneficiaries to guarantee the VIEs’ performance obligations to these third parties, none of these third
parties  can  demand  performance  from  Chuangyi  Technology  as  a  guarantor  of  the  VIEs’  performance  obligations.  The  absence  of  a  written
guarantee agreement, however, does not affect our conclusion that we are the primary beneficiary of the VIEs and in turn should consolidate the
financials of the VIEs. The term of each call option agreement is ten years and such terms can be renewed upon expiration at Chuangyi Technology’s
sole  discretion.  In  January  2016,  shareholders  of  AM  Online,  Linghang  Shengshi  and  Jiaming  Advertising  (except  Yi  Zhang)  entered  into  a
supplement agreement to provide that, without respect to the changes in equity interest percentages of those shareholders in the respective VIEs, the
relevant provisions of the respective call option agreements shall continue to apply.

Equity pledge agreements: Under the equity pledge agreements between Chuangyi Technology and the individual shareholders of our VIEs other
than  AM  Online,  the  individual  shareholders  of  those  VIEs  (except  Yi  Zhang)  pledged  all  of  their  equity  interests,  including  the  right  to  receive
declared dividends, in those VIEs to Chuangyi Technology to guarantee those VIEs’ performance of their obligations under the technology support
and  service  agreement  and  the  technology  development  agreement.  Under  the  equity  pledge  agreements  between  Chuangyi  Technology  and  the
shareholders of AM Online, the shareholders of AM Online (except Yi Zhang) pledged all of their equity interests, including the right to receive
declared  dividends,  in  AM  Online  to  Chuangyi  Technology  to  guarantee  the  performance  by  AM  Online  of  its  obligations  under  its  call  option
agreement  and  its  exclusive  technology  consultation  and  service  agreement.  If  the  VIEs  fail  to  perform  its  obligations  set  forth  in  the  applicable
agreements, Chuangyi Technology shall be entitled to exercise all the remedies and powers set forth in the provisions of the applicable equity pledge
agreements.  Those  agreements  remain  effective  for  as  long  as  the  technology  support  and  service  agreements  and  technology  development
agreement are effective, or, in the case of AM Online, until two years after the term of the obligations under the call option agreement and exclusive
technology consultation and service agreement. Pursuant to the PRC Property Rights Law, an equity pledge is not perfected as a security property
right  unless  it  is  registered  with  the  competent  local  administration  for  industry  and  commerce.  We  have  not  yet  registered  the  share  pledges  by
shareholders  of  AM  Online,  Linghang  Shengshi  and  Jiaming Advertising.  In  January  2016,  shareholders  of  AM  Online,  Linghang  Shengshi  and
Jiaming  Advertising  (except  Yi  Zhang)  entered  into  a  supplement  agreement  to  provide  that,  without  respect  to  the  changes  in  equity  interest
percentages of those shareholders in the respective VIEs, the relevant provisions of the respective equity pledge agreements shall continue to apply.

Authorization letters: Each individual shareholder of the VIEs (except Yi Zhang) has executed an authorization letter to authorize persons appointed
by Chuangyi Technology to exercise certain of its rights, including voting rights, the rights to enter into legal documents and the rights to transfer
any  or  all  of  its  equity  interest  in  the  VIEs. The  authorization  letters  by  the  shareholders  of  our  VIEs  will  remain  effective  during  the  operating
periods  of  the  respective  VIEs  and  for  so  long  as  the  respective  parties  remain  shareholders  of  the  VIEs  unless  terminated  earlier  by  Chuangyi
Technology or unless the call option agreement with respect to VIEs is terminated prior to its expiration.

75

 
 
 
 
 
 
 
Through the above contractual arrangements, Chuangyi Technology has obtained the voting interest in the VIEs of all their shareholders (except Yi Zhang),
has the right to receive substantially all dividends declared and paid by the VIEs and may receive substantially all of the net income of the VIEs through the
technical  support  and  service  fees  as  determined  by  Chuangyi  Technology  at  its  sole  discretion.  Accordingly,  we  have  consolidated  the  VIEs  because  we
believe,  through  the  contractual  arrangements,  (1)  Chuangyi  Technology  could  direct  the  activities  of  the  VIEs  that  most  significantly  affect  its  economic
performance  and  (2)  Chuangyi  Technology  could  receive  substantially  all  of  the  benefits  that  could  be  potentially  significant  to  the  VIEs.  Other  than  the
contractual arrangements described above, because the management and certain employees of Chuangyi Technology also serve in the VIEs as management or
employees, certain operating costs paid by Chuangyi Technology, such as payroll costs and office rental, were re-charged to the VIEs.

Chuangyi Technology also entered into loan agreements with each shareholder of AM Online (except Yi Zhang), pursuant to which Chuangyi Technology
agrees  to  make  loans  in  an  aggregate  amount  of  RMB50  million  to  the  shareholders  of  AM  Online  solely  for  the  incorporation  and  capitalization  of  AM
Online. The loan is interest free and the term of the loan is ten years and shall be automatically renewed on an annual basis unless Chuangyi Technology
objects. Chuangyi Technology can require the shareholders to repay all or a portion of the loan before the maturity date with a 15 days prior written notice.
Under such circumstances, Chuangyi Technology is entitled to, or designate a third party to, buy all or a portion of the shareholders’ equity interests in AM
Online on a pro rata basis based on the amount of the repaid principal of the loan. As of the date of this annual report, no loan had been made and the capital
of AM Online subscribed by shareholders other than Yi Zhang was not injected.

Amounts due from related parties 

As of December 31, 2017, we had $1.0 million due from Mr. Qing Xu, representing an advance to him on a short term basis for personal purpose needs, we
also have $0.5 million and $0.7 million due from AirMedia Holding Ltd. and AirMedia Merger Company Ltd., representing an advance to them on a short
term basis for operation purpose. All the balance has been collected in May 2018, there was no gain or loss upon settlement.

As of December 31, 2018, we had $16 thousand due from Mambo Fiesta Limited., an entity controlled by Mr. Qing Xu, representing an interest free advance
to it on a short term basis for operation purpose. We also have $1 thousand due from Shanghai Qingxuan Co., Ltd., an entity controlled by Mr. Herman Man
Guo, representing an interest free advance to it on a short term basis for operation purpose. In addition, we have $1 thousand due from Global Earning Pacific
Ltd., an entity controlled by Ms. Dan Shao, who is our principal shareholder, representing an interest free advance to it on a short term basis for operation
purpose.

Share Options

See “Item 6. Directors, Senior Management and Employees — B. Compensation — Share Options.”

C.

Interests of Experts and Counsel

Not applicable.

ITEM 8.

FINANCIAL INFORMATION 

A.

Consolidated Statements and Other Financial Information

Financial Statements

We have appended consolidated financial statements filed as part of this annual report. See “Item 18. Financial Statements”.

76

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Legal Proceedings

We may become subject to legal proceedings, investigations and claims incidental to the conduct of our business from time to time.

A  majority  of  the  digital  frames  and  digital  TV  screens  in  the  Company's  network  include  programs  that  consist  of  both  advertising  content  and  non-
advertising content. On December 6, 2007, the State Administration of Radio, Film or Television, or the SARFT, a governmental authority in the PRC, issued
the  Circular  regarding  Strengthening  the  Management  of  Public  Audio-Video  in  Automobiles,  Buildings  and  Other  Public  Areas,  or  the  SARFT  Circular.
According to the SARFT Circular, displaying audio-video programs such as television news, films and television shows, sports, technology and entertainment
through  public  audio-video  systems  located  in  automobiles,  buildings,  airports,  bus  or  train  stations,  shops,  banks  and  hospitals  and  other  outdoor  public
systems must be approved by the SARFT. The Company intends to obtain the requisite approval of the SARFT for the Company's non-advertising content,
but the Company cannot assure that the Company will obtain such approval in compliance with this new SARFT Circular, or at all. In January 2014, the
Company entered into a strategic alliance with China Radio International Oriental Network (Beijing) Co., Ltd ("CRION"), which manages the internet TV
business of China International Broadcasting Network, to operate the CIBN-AirMedia channel for broadcast network TV programs to air travelers in China.
According to the terms of the cooperation arrangement with CRION, during the cooperation period from March 28, 2014 to March 27, 2024, CRION shall
obtain and, from time to time, be responsible for obtaining any approval, license and consent regarding the regulation of broadcasting and television from
relevant authorities.

There is no assurance that CRION will be able to obtain or maintain the requisite approval or the Company will be able to renew the contract with CRION
when they expire. If the requisite approval is not obtained, the Company will be required to eliminate non-advertising content from the programs included in
the Company's digital frames and digital TV screens and advertisers may find the Company's network less attractive and be unwilling to purchase advertising
time  slots  on  the  Company's  network.  As  of  December  31,  2018,  the  Company  did  not  record  a  provision  for  this  matter  as  management  believes  the
possibility of adverse outcome of the matter is remote and any liability it may incur would not have a material adverse effect on its consolidated financial
statements. However, it is not possible for the Company to predict the ultimate outcome and the possible range of the potential impact of failure to obtain such
disclosed registrations and approvals primarily due to the lack of relevant data and information in the market in this industry in the past.

Linghang Shengshi had served a legal letter, dated June 29, 2016 (the “Legal Letter”), on Longde Wenchuang to challenge the proposed transfers by Longde
Wenchuang of their equity interests in AM Advertising to Shanghai Golden Bridge InfoTech Co., Ltd. (stock code: 603918), a PRC company with its shares
listed on the Shanghai Stock Exchange (“Golden Bridge”). As of the date of the Legal Letter, Linghang Shengshi held 24.84% of the equity interests in AM
Advertising. Longde Wenchuang and Culture Center held 28.57% and 46.43%, respectively, of the equity interests in AM Advertising. On June 14, 2016,
Longde  Wenchuang  entered  into  an  equity  interest  transfer  agreement  with  Golden  Bridge  to  transfer  75%  equity  interests  in  AM  Advertising  to  Golden
Bridge in consideration for shares in Golden Bridge (the “Transfer”). Neither of Longde Wenchuang sought consent from Linghang Shengshi with respect to
the Transfer in accordance with the provisions of the Company Law of the People’s Republic of China (the “Company Law”). In the Legal Letter, Linghang
Shengshi challenges the validity of the Transfer on the ground that it violated the statutory right of first refusal of Linghang Shengshi under the Company
Law. Subsequent to the Company’s legal letter, Golden Bridge ceased acquisition of 75% equity interest of AM Advertising from Longde Wenchuang and
Culture Center. Longde Wenchuang and Culture Center further dismissed the Company’s representative from Co-CEO position of AM Advertising.

On  September  2,  2016,  the  Company  received  notice  (the  “September  2,  2016  Notice”)  from  the  China  International  Economic  and  Trade  Arbitration
Commission (the “CIETAC”) that the Company, Chuangyi Technology, Linghang Shengshi and Mr. Herman Man Guo (collectively, the “Respondents”) were
named as respondents by the Culture Center in an arbitration proceeding submitted by the Culture Center to the CIETAC in connection with the sale by the
Company of 75% equity interests in AM Advertising to Culture Center and Longde Wenchuang in June 2015. Culture Center seeks specific performance by
the Respondents of certain obligations under the transaction documents, which include, among other things, (i) the pledge by Linghang Shengshi and Mr. Guo
of their respective equity interests in AM Advertising to Culture Center as security for their obligations under the transaction documents, (ii) the use of best
efforts  by  the  Respondents  to  cooperate  with  the  Culture  Center  and  Longde  Wenchuang  to  procure  the  listing  of  AM  Advertising  in  China  and  (iii)  the
performance by the Company and Mr. Guo of their respective non-compete obligations to refrain from holding, operating, or otherwise participating in any
business that is the same or substantially the same as that of AM Advertising. The Company believes the arbitration request is without merit and intends to
defend  the  actions  vigorously.  However,  no  assurances  can  be  provided  that  the  Company  will  prevail  in  this  arbitration  proceeding.  In  response  to  the
September 2, 2016 Notice, the Company filed a notice against Culture Center to CIETAC for their breach of contract.

77

 
 
 
 
 
 
 
  
 
 
As a result of the above disputes, the Company is no longer able to exercise significant influence in operating and strategic decision of AM Advertising and
cannot access to AM Advertising’s financial information. Accordingly, the Company accounted its investment in AM Advertising using cost method as of
December  31,  2016,  2017  and  2018.  AM  Advertising  and  its  subsidiaries  are  no  longer  related  parties  to  the  Company. As  of  December  31,  2016,  the
Company treated the provision for earnout commitment of $23.5 million as contingent liability and did not record any additional provision for this matter as
management believes the possibility of adverse outcome of the matter is remote and any liability it may incur would not have a material adverse effect on its
consolidated financial statements.

On March 28, 2018, August 23, 2018 and November 2018, a MoU and its supplemental agreements respectively, with, among others, Longde Wenchuang and
Beijing Cultural Center Construction and Development Fund (Limited Partnership), under which, among other things, Linghang Shengshi and Mr. Guo have
agreed to pay or make available to AM Advertising on or prior to May 30, 2018 and further extended to September 30, 2018 and December 31, 2018 an
aggregate of RMB304.6 million which was to be discounted by the following amounts (i) the RMB152 million profits attributable to Linghang Shengshi, Mr.
Guo and Mr. Xu for the first nine months of 2015, based on a third-party pro forma audit report on AM Advertising; (ii) the loan of RMB88.0 million in
principal balance and RMB7.8 million in interests; and (iii) the payment of RMB56.7 million in cash after the sale of the 20.32% equity interests in AM
Advertising, which consisted of 20.18% equity interests hold by the Company and 0.14% equity interests hold by Mr. Man Guo and Mr. Qing Xu on behalf of
the Company, and following the completion of the foregoing arrangements, our obligations with respect to the profit target for 2015, the earnout provision for
the first nine months of 2015 and the loans between AM Advertising and Linghang Shengshi shall be deem completed. According to the aforesaid MoU, after
Linghang Shengshi, Mr. Guo and Mr. Xu transfer all the equity interest of AM Advertising, they will cease to be shareholders of AM Advertising and will not
be able to continuously assume the obligations in connection with the profit commitment and earn out provision as a matter of fact.

As of December 31, 2018, the sale of the 20.32% equity interests in AM Advertising has been completed, while the cash payment of RMB56.7 million to
Longde Wenchuang and Beijing Cultural Center Construction and Development Fund (Limited Partnership) has not been paid yet by the Company. Upon the
effectiveness of MoU, the Company wrote off the contingency of provision for earnout provision, and recorded an actual payable of earnout provision in the
amount of RMB152.6 million, after the deduction loan of RMB88.0 million in principal balance and RMB7.8 million in interests.

On September 29, 2018, SINOPEC Shanghai Oil Products Company (the “SINOPEC Shanghai”) brought before the district court of Huangpu, Shanghai a
legal  action  against  GreatView  Media  and  AM  Advertising.  As  plaintiff,  SINOPEC  Shanghai  plead  to  the  court  a)  to  dissolve  the  advertising  service
agreement and supplementary agreement signed between SINOPEC Shanghai and GreatView Media; b) to support its claim to an overdue concession fee of
RMB  24.4  million  over  the  period  starting  from  September  2009  to  February  2018,  which  may  be  subject  to  change,  payable  by  GreatView  Media;  c)  to
support its claim to an overdue electricity bill of RMB 2.9 million over the period starting from September 2009 to February 2018, which may be subject to
change, payable by GreatView Media; d) to support its claim holding AM Advertising liable to both the overdue concession fee and electricity bill; and e) to
support its claim that the legal fees shall be borne by the defendants. As of December 31, 2018, the Company did not record a provision for this matter as the
management believes the possibility of adverse outcome of the matter is remote and the liability it may incur would not have a material adverse effect on its
consolidated financial statements. In February 2019, RMB 27.3 million has been paid to the court by Linghang Shengshi on behalf of GreatView Media as
security of this matter, which will be returned to the Company after the case closes if the Company wins the case. As of the date of this annual report, the
Company  is  not  able  to  predict  the  ultimate  outcome  and  the  possible  range  of  the  potential  impact  of  failure  primarily  due  to  the  legal  action  has  just
proceeded with the first court appearance and an exchange of evidence between the plaintiff and the defendants.

For risks and uncertainties relating to the pending cases against us, please see “Item 3. Key Information—D. Risk Factors—Risks Related to Our Business—
We have been named as a defendant or respondent in legal proceedings that could have a material adverse impact on our business, financial condition, results
of operation, cash flows and reputation.”

We are not currently a party to, nor are we aware of, any other legal proceeding, investigation or claim which, in the opinion of our management, is likely to
have a material adverse effect on our business, financial condition or results of operations.

Dividend Policy

We have never declared or paid any dividends, nor do we have any present plan to pay any cash dividends on our ordinary shares in the foreseeable future.
We currently intend to retain most, if not all, of our available funds and any future earnings to operate and expand our business.

Our board of directors has discretion in deciding whether to distribute dividends, subject to certain restrictions under Cayman Islands law, namely that our
company may only pay dividends out of profits or share premium account, and provided always that in no circumstances may a dividend be paid if this would
result in our company being unable to pay its debts due in the ordinary course of business. In addition, our shareholders may by ordinary resolution declare a
dividend, but no dividend may exceed the amount recommended by our directors. Even if our board of directors decides to pay dividends, the timing, amount
and form of future dividends, if any, will depend on, among other things, our future results of operations and cash flow, our capital requirements and surplus,
the amount of distributions, if any, received by us from our subsidiaries, our financial condition, contractual restrictions and other factors deemed relevant by
our board of directors.

If we pay any dividends, we will pay our ADS holders to the same extent as holders of our ordinary shares, subject to the terms of the deposit agreement,
including the fees and expenses payable thereunder. Cash dividends on our ordinary shares, if any, will be paid in U.S. dollars.

B.

Significant Changes

Except  as  disclosed  elsewhere  in  this  annual  report,  we  have  not  experienced  any  significant  change  since  the  date  of  our  audited  consolidated  financial
statements filed as part of this annual report.

ITEM 9.

THE OFFER AND LISTING 

A.

Offer and Listing Details

See “—C. Markets.”

B.

Plan of Distribution

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Not applicable.

78

 
 
 
C.

Markets

Our ADSs, each representing ten of our ordinary shares, were listed on the Nasdaq Global Market on November 7, 2007 and were subsequently transferred to
the Nasdaq Global Select Market. Our ADSs, each representing ten of our ordinary shares, has been transferred to The Nasdaq Capital Market in November
2018.  Effective  on  April  11,  2019,  we  adjusted  the  ratio  of  our  ADSs  to  ordinary  shares  from  one  ADS  representing  two  ordinary  shares  to  one  ADS
representing ten ordinary shares.

D.

Selling Shareholders

Not applicable.

E.

Dilution

Not applicable.

F.

Expenses of the Issue

Not applicable.

ITEM 10.

ADDITIONAL INFORMATION 

A.

Share Capital

Not applicable.

B.

Memorandum and Articles of Association

The following are summaries of material terms and provisions of our amended and restated memorandum and articles of association and the Companies Law
(2018  Revision)  of  the  Cayman  Islands,  or  the  Companies  Law,  insofar  as  they  relate  to  the  material  terms  of  our  ordinary  shares.  This  summary  is  not
complete, and you should read our amended and restated memorandum and articles of association, which has been filed as Exhibit 99.3 to our Form 6-K (File
No. 001-33765) filed with the SEC on December 10, 2009, and the amendment thereto, which has been filed as Exhibit 99.2 to our Form 6-K (File No. 001-
33765) filed with the SEC on June 27, 2013. We subsequently amended our memorandum and articles of association by shareholders’ resolutions passed on
July 18, 2013, the results of which have been filed as Exhibit 99.1 to our Form 6-K (File No. 001-33765) filed with the SEC on July 23, 2013.

Registered Office and Objects

Our registered office in the Cayman Islands is located at the offices of Maples Corporate Services Limited, P.O. Box 309, Ugland House, Grand Cayman,
KY1-1104, Cayman Islands, or at such other place as our board of directors may from time to time decide. The objects for which our company is established
are unrestricted and we have full power and authority to carry out any object not prohibited by the Companies Law, as amended from time to time, or any
other law of the Cayman Islands.

Board of Directors

See “Item 6. Directors, Senior Management and Employees — A. Directors and Senior Management.”

Ordinary Shares

General

Our  authorized  share  capital  is  US$1,000,000  consisting  of  900,000,000  ordinary  shares  with  a  nominal  or  par  value  of  US$0.001  each,  and  100,000,000
preferred  shares  with  a  nominal  or  par  value  of  US$0.001  each.  All  of  our  issued  and  outstanding  ordinary  shares  are  fully  paid  and  non-assessable.  Our
ordinary  shares  are  issued  in  registered  form,  and  are  issued  when  registered  in  our  register  of  members.  Our  shareholders  who  are  non-residents  of  the
Cayman Islands may freely hold and vote their ordinary shares. Under our amended and restated memorandum and articles of association, our company may
not issue bearer shares.

79

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Dividend Rights

The holders of our ordinary shares are entitled to such dividends as may be declared by our board of directors. In addition, our shareholders may by ordinary
resolution declare a dividend, but no dividend may exceed the amount recommended by our directors. Under Cayman Islands law, our company may declare
and pay a dividend only out of funds legally available therefor, namely out of either profit or our share premium account, provided that in no circumstances
may we pay a dividend if this would result in our company being unable to pay its debts as they fall due in the ordinary course of business.

Voting Rights

Each ordinary share is entitled to one vote on all matters upon which the ordinary shares are entitled to vote. Voting at any meeting of shareholders is by show
of hands unless a poll is demanded. A poll may be demanded by one or more shareholders holding together at least ten percent of the shares given a right to
vote at the meeting, present in person or by proxy.

A quorum required for a meeting of shareholders consists of shareholders holding not less than an aggregate of one-third of all voting share capital of the
Company in issue present in person or by proxy and entitled to vote. Shareholders’ meetings may be held annually and may be convened by our board of
directors on its own initiative or upon a request to the directors by shareholders holding in aggregate at least one-third of our voting share capital. Advance
notice of at least fourteen days is required for the convening of our annual general meeting and other shareholders meetings.

An ordinary resolution to be passed by the shareholders requires the affirmative vote of a simple majority of the votes attaching to the shares cast in a general
meeting,  while  a  special  resolution  requires  the  affirmative  vote  of  no  less  than  two-thirds  of  the  votes  attaching  to  the  ordinary  shares  cast  in  a  general
meeting.  A  special  resolution  is  required  for  important  matters  such  as  a  change  of  name.  Holders  of  the  ordinary  shares  may  effect  certain  changes  by
ordinary resolution, including increasing the amount of our authorized share capital, consolidating or dividing all or any of our share capital into shares of
larger amount than our existing shares, and canceling any shares that are authorized but unissued. Both an ordinary resolution and a special resolution may
also be passed by a unanimous written resolution signed by all the shareholders of our company, as permitted by the Companies Law and our amended and
restated memorandum and articles of association.

Appointment and Removal of Directors

Our  board  of  directors  may,  by  the  affirmative  vote  of  a  simple  majority  of  the  directors  present  and  voting  at  a  board  meeting,  appoint  any  person  as  a
director, to fill a casual vacancy on the board or as an addition to the existing board. Directors may be removed by special resolution of our shareholders.

Transfer of Shares

Subject to the restrictions of our articles of association, as applicable, any of our shareholders may transfer all or any of his or her shares by an instrument of
transfer in writing and executed by or on behalf of the transferor, accompanied by the certificates of such shares and such other evidence as the Directors may
reasonably require to show the right of the shareholder to make the transfer.

Redemption, Repurchase and Surrender of Shares    

We may issue shares on terms that such shares are subject to redemption, at our option or at the option of the holders, on such terms and in such manner as
may be determined by our board of directors. Our company may also repurchase any of our shares provided that the manner and terms of such purchase have
been approved by ordinary resolution of our shareholders, or are otherwise authorized by our amended and restated memorandum and articles of association.
Under the Companies Law, the redemption or repurchase of any share may be paid out of our company’s profits or out of the proceeds of a fresh issue of
shares  made  for  the  purpose  of  such  redemption  or  repurchase,  or  out  of  capital  (including  share  premium  account  and  capital  redemption  reserve)  if  the
company can, immediately following such payment, pay its debts as they fall due in the ordinary course of business. In addition, under the Companies Law no
such  share  may  be  redeemed  or  repurchased  (a)  unless  it  is  fully  paid  up,  (b)  if  such  redemption  or  repurchase  would  result  in  there  being  no  shares
outstanding,  or  (c)  if  the  company  has  commenced  liquidation.  In  addition,  our  company  may  accept  the  surrender  of  any  fully  paid  share  for  no
consideration.

80

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Liquidation

On  a  winding  up  of  our  company,  the  liquidator  may,  with  the  sanction  of  an  ordinary  resolution  of  our  shareholders,  divide  amongst  the  shareholders
in species or in kind the whole or any part of the assets of our company, and may for that purpose value any assets and determine how the division shall be
carried out as between our shareholders or different classes of shareholders.

Calls on Shares and Forfeiture of Shares

Our board of directors may from time to time make calls upon shareholders for any amounts unpaid on their shares in a notice served to such shareholders at
least fourteen calendar days prior to the specified time and place of payment. Shares that have been called upon and remain unpaid on the specified time are
subject to forfeiture.

Variations of Rights of Shares

If at any time, our share capital is divided into different classes of shares, all or any of the special rights attached to any class of shares may be varied either
with the written consent of the holders of a majority of the issued shares of that class, or with the sanction of a special resolution passed at a separate general
meeting of the holders of shares of that class. The rights conferred upon the holders of the shares of any class issued with preferred or other rights will not,
unless otherwise expressly provided by the terms of issue of the shares of that class, be deemed to be varied by the creation or issue of further shares ranking
pari passu with such existing class of shares.

Inspection of Books and Records

Holders of our ordinary shares will have no general right under Cayman Islands law to inspect or obtain copies of our list of shareholders or our corporate
records. However, we will provide our shareholders with annual audited financial statements.

Changes in Capital    

Our shareholders may from time to time by ordinary resolution:

·
·
·

·

increase our share capital by such sum, to be divided into shares of such classes and amount, as the resolution shall prescribe;
consolidate and divide all or any of our share capital into shares of a larger amount than our existing shares;
sub-divide our existing shares, or any of them into shares of a smaller amount, provided that in the subdivision the proportion between the amount
paid and the amount, if any, unpaid on each reduced share shall be the same as it was in case of the share from which the reduced share is derived; or
cancel any shares that, at the date of the passing of the resolution, have not been taken or agreed to be taken by any person and diminish the amount
of our share capital by the amount of the shares so cancelled.

Our shareholders may, by special resolution and subject to confirmation by the Grand Court of the Cayman Islands on an application by our company for an
order confirming such reduction, reduce our share capital and any capital redemption reserve in any manner authorized by law.

81

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Issuance of Additional Shares

Our amended and restated memorandum and articles of association authorizes our board of directors to issue additional ordinary shares from time to time as
our board of directors shall determine, to the extent there are available authorized but unissued shares.

Our amended and restated memorandum and articles of association authorizes our board of directors to establish from time to time one or more series of
convertible redeemable preferred shares and to determine, with respect to any series of convertible redeemable preferred shares, the terms and rights of that
series, including:

·
·
·
·

designation of the series;
the number of shares of the series;
the dividend rights, conversion rights and voting rights; and
the rights and terms of redemption and liquidation preferences.

The  issuance  of  convertible  redeemable  preferred  shares  may  be  used  as  an  anti-takeover  device  without  further  action  on  the  part  of  the  shareholders.
Issuance of these shares may dilute the voting power of holders of ordinary shares.

Anti-Takeover Provisions

Some provisions of our amended and restated memorandum and articles of association may discourage, delay or prevent a change of control of our company
or management that shareholders may consider favorable, including provisions that:

·

·

authorize  our  board  of  directors  to  issue  preferred  shares  in  one  or  more  series  and  to  designate  the  price,  rights,  preferences,  privileges  and
restrictions of such preferred shares without any further vote or action by our shareholders; and

limit the ability of shareholders to requisition and convene general meetings of shareholders.

However, under Cayman Islands law, our directors may only exercise the rights and powers granted to them under our amended and restated memorandum
and articles of association for a proper purpose and for what they believe in good faith to be in the best interests of our company.

See “— H. Documents on Display.”

C.

Material Contracts

We have not entered into any material contracts other than in the ordinary course of business and other than those described above, in “Item 4. Information on
the Company” or elsewhere in this annual report on Form 20-F.

D.

Exchange Controls

There  are  no  material  exchange  controls  restrictions  on  payment  of  dividends,  interest  or  other  payments  to  the  holders  of  our  ordinary  shares  or  on  the
conduct of our operations in the Cayman Islands, where we were incorporated. Cayman Islands law and our memorandum and articles of association do not
impose any material limitations on the right of nonresidents or foreign owners to hold or vote our ordinary shares.

See  “Item  4.  Information  on  the  Company  —  B.  Business  Overview  —  Regulation  —  Regulations  on  Foreign  Exchange”  for  a  description  of  PRC
regulations on foreign exchange.

82

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
E.

Taxation

Cayman Islands Taxation  

The Cayman Islands currently levies no taxes on individuals or corporations based upon profits, income, gains or appreciation and there is no taxation in the
nature of inheritance tax or estate duty. No Cayman Islands stamp duty will be payable unless an instrument is executed in, or after execution, brought to or
produced before a court in the Cayman Islands.

The Cayman Islands is not party to any double tax treaties that are applicable to any payments made to or by our company. There are no exchange control
regulations or currency restrictions in the Cayman Islands. Payments of dividends and capital in respect of the ordinary shares will not be subject to taxation
in the Cayman Islands and no withholding will be required on the payment of a dividend or capital to any holder of the ordinary shares, nor will gains derived
from the disposal of the ordinary shares be subject to Cayman Islands income or corporation tax.

PRC Taxation

Under the EIT Law and its implementation rules, foreign corporate shareholders and corporate ADSs holders may be subject to a 10% income tax upon the
dividends  payable  by  us  or  on  any  gains  they  realize  from  the  transfer  of  our  shares  or  ADSs,  if  we  are  classified  as  a  PRC  resident  enterprise  and  such
income is regarded as income from “sources within the PRC.” Given the fact that whether we would be regarded as “resident enterprise” is not clear, it is
uncertain whether foreign corporate shareholders and corporate ADSs holders may be subject to a 10% income tax upon the dividends payable by us or on
any  gains  they  realize  from  the  transfer  of  our  shares  or  ADSs.  If  we  are  required  under  the  PRC  tax  law  to  withhold  PRC  income  tax  on  our  dividends
payable to our non-PRC corporate shareholders and ADS holders or if any gains of the transfer of their shares or ADSs are subject to PRC tax, such holders’
investment in our ADSs or ordinary shares may be materially and adversely affected.

United States Federal Income Taxation  

The following is a summary of U.S. federal income tax considerations generally applicable to the ownership and disposition of our ADSs or ordinary shares
by  a  U.S.  Holder  (as  defined  below)  that  holds  our  ADSs  or  ordinary  shares  as  “capital  assets”  (generally,  property  held  for  investment)  under  the  U.S.
Internal  Revenue  Code  of  1986,  as  amended,  or  the  Code,  but  it  does  not  purport  to  be  a  complete  analysis  of  all  potential  tax  consequences  and
considerations. This summary is based upon existing U.S. federal income tax law as of the date hereof, which is subject to differing interpretations or change,
possibly with retroactive effect. This summary does not discuss all aspects of U.S. federal income taxation that may be important to particular holders in light
of  their  individual  circumstances,  including  holders  subject  to  special  tax  rules  (for  example,  banks  or  other  financial  institutions,  insurance  companies,
regulated  investment  companies,  real  estate  investment  trusts,  cooperatives,  pension  plans,  broker-dealers,  partnerships  and  their  partners,  and  tax-exempt
organizations (including private foundations)), holders who are not U.S. Holders, holders who own (directly, indirectly or constructively) 10% or more of our
stock (by vote or value), holders who acquire their ADSs or ordinary shares pursuant to any employee share option or otherwise as compensation, holders that
hold  their  ADSs  or  ordinary  shares  as  part  of  a  straddle,  hedge,  conversion,  constructive  sale  or  other  integrated  transaction  for  U.S.  federal  income  tax
purposes, investor required to accelerate the recognition of any item of gross income with respect to our ADSs or ordinary shares as a result of such income
being recognized on an applicable financial statement, traders in securities that have elected the mark-to-market method of accounting for their securities or
holders  that  have  a  functional  currency  other  than  the  United  States  dollar,  all  of  whom  may  be  subject  to  tax  rules  that  differ  significantly  from  those
summarized below. In addition, this summary does not discuss any alternative minimum tax, state, local, non-U.S. tax or non-income tax (such as the United
States federal gift and estate tax) considerations or the Medicare tax. Each U.S. Holder is urged to consult with its tax advisor regarding the U.S. federal, state,
local, and non-U.S. income and other tax considerations relating to the ownership and disposition of our ADSs or ordinary shares.

83

 
 
 
 
 
 
 
 
 
 
 
 
General

For  purposes  of  this  summary,  a  “U.S.  Holder”  is  a  beneficial  owner  of  our  ADSs  or  ordinary  shares  that  is,  for  U.S.  federal  income  tax  purposes,  (i)  an
individual who is a citizen or resident of the United States, (ii) a corporation (or other entity treated as a corporation for U.S. federal income tax purposes)
created in, or organized under the law of, the United States or any state thereof or the District of Columbia, (iii) an estate the income of which is includible in
gross income for U.S. federal income tax purposes regardless of its source, or (iv) a trust (A) the administration of which is subject to the primary supervision
of a United States court and which has one or more United States persons who have the authority to control all substantial decisions of the trust or (B) that has
otherwise elected to be treated as a United States person.

If a partnership (or other entity treated as a partnership for U.S. federal income tax purposes) is a beneficial owner of our ADSs or ordinary shares, the tax
treatment of a partner in the partnership will generally depend upon the status of the partner and the activities of the partnership. Partnerships holding our
ADSs or ordinary shares and partners in such partnerships are urged to consult their tax advisors regarding their ownership and disposition of our ADSs or
ordinary shares.

It is generally expected that a U.S. Holder of ADSs should be treated as the beneficial owner, for United States federal income tax purposes, of the underlying
shares represented by the ADSs. The remainder of this discussion assumes that a holder of ADSs will be treated in this manner. Accordingly, deposits or
withdrawals of ordinary shares for ADSs will not be subject to United States federal income tax.

Passive Foreign Investment Company Considerations

Based on the market price of our ADSs and the composition of our assets (in particular, the retention of a large amount of cash), we believe that we were a
PFIC, for United States federal income tax purposes, for the taxable year ended December 31, 2018, and we will very likely be classified as a PFIC for our
current taxable year ending December 31, 2019 unless the market price of our ADSs increases and/or we invest a substantial amount of the cash and other
passive assets we hold in assets that produce or are held for the production of non-passive income. In general, we will be classified as a PFIC for any taxable
year if either (i) 75 percent or more of our gross income for such year is passive income or (ii) 50 percent or more of the average quarterly value of our assets
(as generally determined on the basis of fair market value) produce or are held for the production of passive income. For this purpose, cash and assets readily
convertible into cash are generally classified as passive and goodwill and other unbooked intangibles associated with active business activities may generally
be classified as non-passive. We will be treated as owning a proportionate share of the assets and earning a proportionate share of the income of any other
corporation in which we own, directly or indirectly, 25 percent or more (by value) of the stock. Although the law in this regard is unclear, we treat the VIEs
(and their subsidiaries) as being owned by us for U.S. federal income tax purposes, not only because we exercise effective control over the operations of such
entities  but  also  because  we  are  entitled  to  substantially  all  of  the  economic  benefits  associated  with  such  entities,  and,  as  a  result,  we  consolidate  such
entity’s’ operating results in our consolidated financial statements. Because there are uncertainties in the application of the relevant rules and PFIC status is a
fact-intensive determination made on an annual basis, no assurance can be given with respect to our PFIC status for any taxable year.

If we are classified as a PFIC for any year during which a U.S. Holder holds ADSs or ordinary shares, a U.S. Holder will generally, as discussed below under
“—Passive  Foreign  Investment  Company  Rules,”  be  treated  as  holding  an  equity  interest  in  a  PFIC  in  the  first  taxable  year  of  the  U.S.  Holder’s  holding
period in which we are or become a PFIC and subsequent taxable years (“PFIC-Tainted Shares”) even if, we in fact, cease to be a PFIC in subsequent taxable
years.

Passive Foreign Investment Company Rules

As mentioned above, we believe that we were a PFIC for the taxable year ended December 31, 2018, and we will very likely be classified as a PFIC for our
current  taxable  year  ending  December  31,  2019.  If  we  are  classified  as  a  PFIC  for  any  taxable  year  during  which  a  U.S.  Holder  holds  ADSs  or  ordinary
shares, and unless a mark-to-market election (as described below) is made, a U.S. Holder will generally be subject to special tax rules that have a penalizing
effect, regardless of whether we remain a PFIC, on (i) any excess distribution that we make (which generally means any distribution received in a taxable year
that is greater than 125 percent of the average annual distributions received in the three preceding taxable years or such U.S. Holder’s holding period for the
ADSs or ordinary shares, if shorter), and (ii) any gain realized on the sale or other disposition, including a pledge, of our ADSs or ordinary shares. Under the
PFIC rules:

84

 
 
 
 
 
 
 
 
 
 
 
 
 
·

·

·

·

such excess distribution or gain will be allocated ratably over the U.S. Holder’s holding period for the ADSs or ordinary shares;  

such amount allocated to the current taxable year and any taxable year prior to the first taxable year in which we are classified as a PFIC (a “pre-
PFIC year”) will be taxable as ordinary income;  

such amount allocated to each prior taxable year, other than a pre-PFIC year, will be subject to tax at the highest tax rate in effect applicable to such
U.S. Holder for that year; and 

an interest charge generally applicable to underpayments of tax will be imposed on the tax attributable to each prior taxable year, other than a pre-
PFIC year.  

If we are a PFIC for any taxable year during which a U.S. Holder holds ADSs or ordinary shares and any of our non-United States subsidiaries is also a PFIC,
such U.S. Holder would be treated as owning a proportionate amount (by value) of the ADSs or ordinary shares of the lower-tier PFIC and would be subject
to the rules described above on certain distributions by a lower-tier PFIC and a disposition of ADSs or ordinary shares of a lower-tier PFIC even though such
U.S. Holder would not receive the proceeds of those distributions or dispositions.

As an alternative to the foregoing rules, a holder of “marketable stock” in a PFIC may make a mark-to-market election with respect to such stock. Marketable
stock is stock that is regularly traded on a qualified exchange or other market as defined in applicable United States Treasury Regulations. Our ADSs (but not
our ordinary shares) are listed on the Nasdaq Capital Market, which is a qualified exchange or other market for these purposes. We anticipate that the ADSs
will be considered regularly traded for so long as they continue to be listed, but no assurance may be given in this regard. If a U.S. Holder makes this election,
such holder will generally (i) include in gross income for each taxable year the excess, if any, of the fair market value of the ADSs at the end of the taxable
year over the adjusted tax basis of the ADSs and (ii) deduct as an ordinary loss the excess, if any, of the adjusted tax basis of the ADSs over the fair market
value of the ADSs at the end of the taxable year, but only to the extent of the amount previously included in income as a result of the mark-to-market election.
The adjusted tax basis in the ADSs would be adjusted to reflect any income or loss resulting from the mark-to-market election. If a mark-to-market election is
made in respect of a corporation classified as a PFIC and such corporation ceases to be classified as a PFIC, a U.S. Holder will generally not be required to
take into account the gain or loss described above during any period that such corporation is not classified as a PFIC. If a mark-to-market election is made,
any gain recognized upon the sale or other disposition of ADSs will be treated as ordinary income and any loss will be treated as ordinary loss, but such loss
will only be treated as ordinary to the extent of the net amount previously included in income as a result of the mark-to-market election. In the case of a U.S.
Holder who has held ADSs during any taxable year in which we are classified as PFIC and continues to hold such ADSs (or any portion thereof), and who is
considering making a mark-to-market election, special tax rules may apply relating to purging the PFIC taint of such ADSs. If a U.S. Holder makes a mark-
to-market election, the tax rules that apply to distributions by corporations which are not PFICs would apply to distributions, except that the reduced tax rate
applicable to qualified dividend income (as discussed below in “ –Dividends”) would not apply.

Because a mark-to-market election cannot be made for any lower-tier PFICs that we may own, a U.S. Holder may continue to be subject to the PFIC rules
with respect to such U.S. Holder’s indirect interest in any investment held by us that is treated as an equity interest in a PFIC for United States federal income
tax purposes.

We  do  not  intend  to  provide  the  U.S.  Holders  with  the  information  necessary  to  permit  U.S.  Holders  to  make  qualified  electing  fund  elections,  which,  if
available, would result in tax treatment different from (and generally less adverse than) the general tax treatment for PFICs described above.

If a U.S. Holder owns our ADSs or ordinary shares during any taxable year that we are a PFIC, the holder must generally file an annual IRS Form 8621. Each
U.S.  Holder  is  urged  to  consult  its  tax  advisor  concerning  the  United  States  federal  income  tax  consequences  of  holding  and  disposing  ADSs  or  ordinary
shares if we are or become a PFIC, including the possibility of making a mark-to-market election, the “deemed sale” and “deemed dividend” elections.

85

 
 
 
 
 
 
 
 
 
 
 
 
 
Dividends

Subject to the PFIC rules discussed above, any cash distributions (including the amount of any taxes withheld) paid on our ADSs or ordinary shares out of our
current or accumulated earnings and profits, as determined under U.S. federal income tax principles, will generally be includible in the gross income of a U.S.
Holder as dividend income on the day actually or constructively received by the U.S. Holder, in the case of ordinary shares, or by the depositary, in the case
of  ADSs.  Because  we  do  not  intend  to  determine  our  earnings  and  profits  on  the  basis  of  U.S.  federal  income  tax  principles,  any  distribution  paid  will
generally be reported as a “dividend” for U.S. federal income tax purposes. A non-corporate recipient of dividend income generally will be subject to tax on
dividend income from a “qualified foreign corporation” at a reduced U.S. federal tax rate rather than the marginal tax rates generally applicable to ordinary
income provided that certain holding period requirements are met.

A  non-United  States  corporation  (other  than  a  corporation  that  is  classified  as  a  PFIC  for  the  taxable  year  in  which  the  dividend  is  paid  or  the  preceding
taxable year) generally will be considered to be a qualified foreign corporation with respect to any dividend it pays on stock (or ADSs in respect of such
stock) which is readily tradable on an established securities market in the United States or, in the event that the company is deemed to be a PRC resident
under the PRC Enterprise Income Tax Law, the company is eligible for the benefits of the United States-PRC treaty.

Dividends received on the ADSs or ordinary shares are not expected to be eligible for the dividends received deduction allowed to corporations.

Although the ADSs are currently tradable on the Nasdaq Capital Market, which is an established securities market in the United States, and thus we anticipate
they will be considered readily tradable on an established securities market in the United States for purposes of the reduced tax rate, no assurance may be
given in this regard. Furthermore, as mentioned above, we believe that we were a PFIC for the taxable year ended December 31, 2018, and we will very likely
be classified as a PFIC for our current taxable year ending December 31, 2019. Each U.S. Holder is advised to consult its tax advisor regarding the rate of tax
that will apply to such holder with respect to, dividend distributions, if any, received from us.

Dividends paid on our ADSs or ordinary shares generally will be treated as income from foreign sources for United States foreign tax credit purposes and
generally will constitute passive category income. A U.S. Holder may be eligible, subject to a number of complex limitations, to claim a foreign tax credit in
respect of any foreign withholding taxes imposed on dividends received on our ADSs or ordinary shares. A U.S. Holder who does not elect to claim a foreign
tax credit for foreign tax withheld, may instead claim a deduction, for U.S. federal income tax purposes, in respect of such withholdings, but only for a year in
which such holder elects to do so for all creditable foreign income taxes. The rules governing the foreign tax credit are complex. Each U.S. Holder is advised
to consult its tax advisor regarding the availability of the foreign tax credit under their particular circumstances.

Sale or Other Disposition of ADSs or Ordinary Shares

Subject to the PFIC rules discussed above, a U.S. Holder generally will recognize capital gain or loss upon the sale or other disposition of ADSs or ordinary
shares in an amount equal to the difference between the amount realized upon the disposition and the holder’s adjusted tax basis in such ADSs or ordinary
shares. Any capital gain or loss will be long-term if the ADSs or ordinary shares have been held for more than one year and will generally be United States
source gain or loss for United States foreign tax credit purposes. The deductibility of a capital loss is subject to limitations. Each U.S. Holder is advised to
consult with its tax advisor regarding the tax consequences if a foreign withholding tax is imposed on a disposition of our ADSs or ordinary shares, including
the availability of the foreign tax credit under their particular circumstances.

F.

Dividends and Paying Agents

Not applicable.

G.

Statement by Expert

Not applicable.

86

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
H.

Documents on Display

We are subject to the periodic reporting and other informational requirements of the Exchange Act. Under the Exchange Act, we are required to file reports
and other information with the SEC. Specifically, we are required to file annually a Form 20-F within four months after the end of each fiscal year. Copies of
reports  and  other  information,  when  so  filed,  may  be  inspected  without  charge  and  may  be  obtained  at  prescribed  rates  at  the  public  reference  facilities
maintained  by  the  SEC  at  100  F  Street,  N.E.,  Room  1580,  Washington,  D.C.,  20549.  The  public  may  obtain  information  regarding  the  Washington,  D.C.
Public Reference Room by calling the Commission at 1-800-SEC-0330. The SEC also maintains a web site at www.sec.gov that contains reports, proxy and
information statements, and other information regarding registrants that make electronic filings with the SEC using its EDGAR system. As a foreign private
issuer, we are exempt from the rules under the Exchange Act prescribing the furnishing and content of quarterly reports and proxy statements, and officers,
directors and principal shareholders are exempt from the reporting and short-swing profit recovery provisions contained in Section 16 of the Exchange Act.

We will furnish JPMorgan Chase Bank, N. A., the depositary of our ADSs, with our annual reports, which will include a review of operations and annual
audited  consolidated  financial  statements  prepared  in  conformity  with  U.S.  GAAP,  and  all  notices  of  shareholders’  meetings  and  other  reports  and
communications  that  are  made  generally  available  to  our  shareholders.  The  depositary  will  make  such  notices,  reports  and  communications  available  to
holders of ADSs and, upon our request, will mail to all record holders of ADSs the information contained in any notice of a shareholders’ meeting received
by the depositary from us.

In  accordance  with  Nasdaq  Stock  Market  Rule  5250(d),  we  will  post  this  annual  report  on  Form  20-F  on  our  website  at  http://www.airmedia.net.cn.  In
addition, we will provide hardcopies of our annual report free of charge to shareholders and ADS holders upon request.

I.

Subsidiary Information

Not applicable.

ITEM 11.

QUANTITATIVE AND QUALITATIVE DISCLOSURES ABOUT MARKET RISK 

Interest Rate Risk

Our exposure to interest rate risk primarily relates to the interest income generated by excess cash, which is mostly held in interest-bearing bank deposits. We
have not used derivative financial instruments in our investment portfolio. Interest-earning instruments carry a degree of interest rate risk. We have not been
exposed nor do we anticipate being exposed to material risks due to changes in market interest rates. However, our future interest income may fall short of
expectations due to changes in market interest rates. A hypothetical 1% decrease in interest rates would have resulted in a decrease of approximately $0.1
million in our interest income for the year ended December 31, 2018.

Foreign Exchange Risk

Our financial statements are expressed in U.S. dollars, which is our reporting and functional currency. However, substantially all of the revenues and expenses
of our consolidated operating subsidiaries and affiliate entities are denominated in RMB. Substantially all of our sales contracts are denominated in RMB and
substantially all of our costs and expenses are denominated in RMB. We have not had any material foreign exchange gains or losses. Although in general, our
exposure to foreign exchange risks should be limited, the value of your investment in our ADSs will be affected by the foreign exchange rate between U.S.
dollars and RMB because the value of the business of our operating subsidiaries and VIEs is effectively denominated in RMB, while the ADSs are traded in
U.S. dollars.

The conversion of RMB into foreign currencies, including U.S. dollars, is based on rates set by the People’s Bank of China. The PRC government allowed the
RMB to appreciate by more than 20% against the U.S. dollar between July 2005 and July 2008. Between July 2008 and June 2010, this appreciation halted
and the exchange rate between RMB and the U.S. dollar remained within a narrow band. As a consequence, the RMB fluctuated significantly during that
period against other freely traded currencies, in tandem with the U.S. dollar. Since June 2010, the PRC government has allowed the RMB to appreciate slowly
against the U.S. dollar again. It is difficult to predict how market forces or PRC or U.S. government policy may impact the exchange rate between the RMB
and the U.S. dollar in the future. We have not used any forward contracts or currency borrowings to hedge our exposure to foreign currency exchange risk.

87

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
To the extent that we need to convert our U.S. dollar-denominated assets into RMB for our operations, appreciation of the RMB against the U.S. dollar would
have an adverse effect on RMB amount we receive from the conversion. A hypothetical 10% decrease in the exchange rate of the U.S. dollar against RMB
would have resulted in a decrease of $0.2 million in the value of our U.S. dollar-denominated financial assets at December 31, 2018. Conversely, if we decide
to convert our RMB-denominated cash amounts into U.S. dollars for the purpose of making payments for dividends on our ordinary shares or ADSs or for
other business purposes, appreciation of the U.S. dollar against RMB would have a negative effect on the U.S. dollar amount available to us.

Inflation

Inflationary factors such as increases in the cost of our product and overhead costs may adversely affect our operating results. Although we do not believe that
inflation has had a material impact on our financial position or results of operations to date, a high rate of inflation in the future may have an adverse effect on
our ability to maintain current levels of gross margin and selling, general and administrative expenses as a percentage of net revenues if the selling prices of
our products do not increase with these increased costs.

ITEM 12.

DESCRIPTION OF SECURITIES OTHER THAN EQUITY SECURITIES 

A.

Debt Securities

Not applicable.

B.

Warrants and Rights

Not applicable.

C.

Other Securities

Not applicable.

D.

American Depositary Shares

Fees and Charges Our ADS Holders May Have to Pay

JPMorgan Chase Bank, N. A., the depositary of our ADS program, collects its fees for delivery and surrender of ADSs directly from investors depositing
shares or surrendering ADSs for the purpose of withdrawal or from intermediaries acting for them. The depositary collects fees for making distributions to
investors by deducting those fees from the amounts distributed or by selling a portion of distributable property to pay the fees. The depositary may collect its
annual  fee  for  depositary  services  by  deductions  from  cash  distributions  or  by  directly  billing  investors  or  by  charging  the  book-entry  system  accounts  of
participants acting for them. The depositary may generally refuse to provide fee-attracting services until its fees for those services are paid.  

88

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Persons depositing or withdrawing shares must pay:

$5.00 per 100 ADSs (or portion of 100 ADSs)

For:
Issuance of ADSs, including issuances resulting from a distribution of shares
or  rights  or  other  property;  cancellation  of  ADSs  for  the  purpose  of
withdrawal, including if the deposit agreement terminates

$0.05 (or less) per ADS

  Any cash distribution to registered ADS holders

A fee equivalent to the fee that would be payable if securities distributed had
been  shares  and  the  shares  had  been  deposited  for  issuance  of  ADSs  $0.05
(or less) per ADSs per calendar year (if the depositary has not collected any
cash distribution fee during that year)

  Distribution of securities distributed to holders of deposited securities which
are  distributed  by  the  depositary  to  registered  ADS  holders  Depositary
services

Expenses of the depositary

Registration or transfer fees

  Cable,  telex  and  facsimile  transmissions  (when  expressly  provided  in  the

deposit agreement); converting foreign currency to U.S. dollars

  Transfer and registration of shares on our share register to or from the name

of the depositary or its agent when you deposit or withdraw shares

Taxes and other governmental charges the depositary or the custodian have to
pay  on  any  ADS  or  share  underlying  an  ADS,  for  example,  stock  transfer
taxes, stamp duty or withholding taxes

  As necessary

Any  charges  incurred  by  the  depositary  or  its  agents  for  servicing  the
deposited securities

  As necessary 

Fees and Other Payments Made by the Depositary to Us

The  depositary  has  agreed  to  reimburse  us  annually  for  our  expenses  incurred  in  connection  with  investor  relationship  programs  and  any  other  program
related  to  our  ADS  facility  and  the  travel  expense  of  our  key  personnel  in  connection  with  such  programs.  The  depositary  has  also  agreed  to  provide
additional payments to us based on the applicable performance indicators relating to our ADS facility. There are limits on the amount of expenses for which
the depositary will reimburse us, but the amount of reimbursement available to us is not necessarily tied to the amount of fees the depositary collects from
investors. We recognize the reimbursable amounts in other income on our consolidated statements of operations on a straight-line basis over the contract term
with the depositary. For the year ended December 31, 2018, we received nil from the depositary as reimbursement for our expenses incurred.  

ITEM 13.

DEFAULTS, DIVIDEND ARREARAGES AND DELINQUENCIES 

PART II

None.

ITEM 14.

MATERIAL MODIFICATIONS TO THE RIGHTS OF SECURITIES HOLDERS AND USE OF PROCEEDS 

See “Item 10. Additional Information” for a description of the rights of securities holders, which remain unchanged.

The following “Use of Proceeds” information relates to the registration statement on Form F-1 (File number: 333-146825) filed by us in connection with our
initial public offering. The registration statement was declared effective by the SEC on November 6, 2007. We received net proceeds of approximately $187.0
million from our initial public offering.

As of December 31, 2018, the net proceeds from our initial public offering  have been used up as follows:  

·

·

approximately $122.4 million for the purchase of digital displays and other equipment and the construction of gas station media platforms;  

approximately $24.8 million for share repurchases; and 

89

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
·

·

approximately $10.1 million for the purchase of long-term investments.  

approximately $29.7 million for business acquisition and the purchase of intangible assets.  

ITEM 15.

CONTROLS AND PROCEDURES 

Disclosure Controls and Procedures  

Our  management,  with  the  participation  of  our  chief  executive  officer  and  chief  financial  officer,  has  performed  an  evaluation  of  the  effectiveness  of  our
disclosure controls and procedures (as defined in Rule 13a-15(e) under the Exchange Act) as of the end of the period covered by this report, as required by
Rule 13a-15(b) under the Exchange Act.

Based upon that evaluation, our management, with the participation of our chief executive officer and chief financial officer, has concluded that, due to the
material  weakness  described  below,  as  of  December  31,  2018,  our  disclosure  controls  and  procedures  were  not  effective  in  ensuring  that  the  information
required to be disclosed by us in the reports that we file and furnish under the Exchange Act was recorded, processed, summarized and reported, within the
time periods specified in the SEC’s rules and forms, and that the information required to be disclosed by us in the reports that we file or submit under the
Exchange Act is accumulated and communicated to our management, including our chief executive officer and chief financial officer, as appropriate, to allow
timely decisions regarding required disclosure.

Management’s Annual Report on Internal Control over Financial Reporting  

Our management is responsible for establishing and maintaining adequate internal control over financial reporting, as such term is defined in Rules 13a-15(f)
and 15d-15(f) under the Securities Exchange Act of 1934. Our internal control over financial reporting is a process designed to provide reasonable assurance
regarding  the  reliability  of  financial  reporting  and  the  preparation  of  consolidated  financial  statements  in  accordance  with  generally  accepted  accounting
principles in the United States of America (“U.S. GAAP”). Internal control over financial reporting includes those policies and procedures that (1) pertain to
the  maintenance  of  records  that,  in  reasonable  detail,  accurately  and  fairly  reflect  the  transactions  and  dispositions  of  a  company’s  assets,  (2)  provide
reasonable  assurance  that  transactions  are  recorded  as  necessary  to  permit  preparation  of  consolidated  financial  statements  in  accordance  with  generally
accepted  accounting  principles,  and  that  a  company’s  receipts  and  expenditures  are  being  made  only  in  accordance  with  authorizations  of  a  company’s
management and directors and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a
company’s assets that could have a material effect on the consolidated financial statements.

Because  of  its  inherent  limitations,  internal  control  over  financial  reporting  may  not  prevent  or  detect  misstatements.  Projections  of  any  evaluation  of
effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance
with the policies or procedures may deteriorate.

As required by Section 404 of the Sarbanes-Oxley Act of 2002 and related rules promulgated by the Securities and Exchange Commission, our management,
including our chief executive officer and chief financial officer, assessed the effectiveness of internal control over financial reporting as of December 31, 2018
using the criteria set forth in the report “Internal Control — Integrated Framework (2013)” published by the Committee of Sponsoring Organizations of the
Treadway Commission (known as COSO).

A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility
that a material misstatement of the company’s annual or interim financial statements will not be prevented or detected on a timely basis.

The  following  material  weakness  in  internal  control  over  financial  reporting  has  been  identified  as  of  December  31,  2018.  The  material  weaknesses  as  of
December 31, 2018 were related to a) the weak operating effectiveness and lack of monitoring of controls over financial reporting due to inadequate resources
or resources with insufficient experience or training in our financial reporting team, internal control team, administration team and human resource team, and
b) lack of internal controls over risk assessments related to third party borrowings resulting in material losses from loans to third parties. 

90

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Because of the material weakness described above, our management has concluded that we had not maintain effective internal control over financial reporting
as of December 31, 2018, based on criteria established in Internal Control — Integrated Framework (2013) issued by COSO.

Internal Control over Financial Reporting 

This annual report does not include an attestation report of our company’s registered public accounting firm as we are a non-accelerated filer as defined in
Rule 12b-2 of the Exchange Act.

Changes in Internal Control over Financial Reporting  

In preparing our consolidated financial statements, we identified a material weakness in our internal control over financial reporting as of December 31, 2018.
As defined in standards established by the PCAOB, a “material weakness” is a deficiency, or combination of deficiencies, in internal control over financial
reporting, such that there is a reasonable possibility that a material misstatement of the annual or interim financial statements will not be prevented or detected
on a timely basis.

The  material  weakness  identified  was  related  to  a)  the  weak  operating  effectiveness  and  lack  of  monitoring  of  controls  over  financial  reporting  due  to
inadequate  resources  or  resources  with  insufficient  experience  or  training  in  our  financial  reporting  team,  internal  control  team,  administration  team  and
human resource team, and b) lack of internal controls over risk assessments related to third party borrowings resulting in material losses from loans to third
parties.

To  remediate  our  identified  material  weakness,  significant  deficiency  and  other  control  deficiencies  in  connection  with  preparation  of  our  consolidated
financial statements, we plan to adopt several measures to improve our internal control over financial reporting. For example, during the reporting period, we
obtained  support  from  an  external  consultant  firm  with  experienced  staff  to  assist  us  in  the  preparation  of  the  financial  statements  for  the  year  ended
December 31, 2018. The consultant firm is well-known in China and many staff hold the AICPA license with a solid understanding of U.S. GAAP. In order to
meet the requirements of internal audit, we outsourced this function department to a professional consulting company with related industry experience and it
delivered the work on time.

Other than as described above, no changes in our internal controls over financial reporting occurred during the period covered by this annual report that have
materially affected, or are reasonably likely to materially affect, our internal controls over financial reporting.

ITEM 16A.

AUDIT COMMITTEE FINANCIAL EXPERT 

Our  board  of  directors  has  determined  that  each  of  Songzuo  Xiang  and  Conor  Chia-hung  Yang,  members  of  our  audit  committee,  is  an  audit  committee
financial expert. Each of Songzuo Xiang and Conor Chia-hung Yang is an independent director as defined by the rules and regulations of the Nasdaq Stock
Market LLC and under Rule 10A-3 under the Exchange Act.  

ITEM 16B.

CODE OF ETHICS 

Our board of directors has adopted a code of ethics that applies to our directors, officers, employees and agents, including certain provisions that specifically
apply to our chief executive officer, chief financial officer, chief operating officer, chief technology officer, presidents, vice presidents and any other persons
who perform similar functions for us. We have filed our code of business conduct and ethics as an exhibit to our registration statement on Form F-1 (No. 333-
146825), as amended, initially filed on October 19, 2007.

91

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ITEM 16C.

PRINCIPAL ACCOUNTANT FEES AND SERVICES 

The following table sets forth the aggregate fees by categories specified below in connection with certain professional services rendered by Marcum Bernstein
& Pinchuk LLP, our current principal external auditors, for the periods indicated. We did not pay any other fees to our auditors during the periods indicated
below.

Audit Fees
Audit-Related Fees
Tax Fees
All Other Fees
TOTAL

  Fiscal Year Ended December 31,

2017

2018

  $

  $

670,153    $
—     
—     
—     
670,153    $

754,129 
— 
— 
— 
754,129 

“Audit  Fees”  consisted  of  the  aggregate  fees  billed  for  professional  services  rendered  for  the  audit  of  our  annual  financial  statements  or  quarterly  review
services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements.

“Audit Related Fees” consisted of the aggregate fees billed for professional services rendered for assurance and related services that were reasonably related
to the performance of the audit or review of our regulatory filings and were not otherwise included in Audit Fees.

“Tax Fees” consisted of the aggregate fees billed for professional services rendered for tax compliance, tax advice and tax planning. Included in such Tax
Fees were fees for preparation of our tax returns and consultancy and advice on other tax planning matters.

“All Other Fees” consisted of the aggregate fees billed for products and services provided and not otherwise included in Audit Fees, Audit Related Fees or
Tax Fees.

The policy of our audit committee is to pre-approve all audit and non-audit services provided by our external auditors, including audit services, audit-related
services, tax services and other services as described above, other than those for de minimus services which are approved by the audit committee prior to the
completion of the audit.

ITEM 16D.

EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES 

We have not asked for, nor have we been granted, an exemption from the applicable listing standards for our audit committee.

ITEM 16E.

PURCHASES OF EQUITY SECURITIES BY THE ISSUER AND AFFILIATED PURCHASERS

We announced on March 28, 2018 and further updated on September 28, 2018 that Mr. Herman Man Guo intended to purchase AirMedia’s ordinary shares in
the form of ADSs with an aggregate value of up to $5 million. As of the date of this annual report, Mr. Herman Man Guo acquired, an aggregate of 344,984
ADSs, representing 3,449,844 ordinary shares of us.

ITEM 16F.

CHANGE IN REGISTRANT’S CERTIFYING ACCOUNTANT 

Effective  from  March  3,  2017,  we  engaged  Marcum  Bernstein  &  Pinchuk  LLP  as  our  independent  registered  public  accounting  firm.  We  also  dismissed
Deloitte on the same date. The decision was not made due to any disagreements with Deloitte. The change of our independent registered public accounting
firm was approved by the audit committee of our board on March 3, 2017.

Other  than  an  adverse  opinion  on  our  internal  control  over  financial  reporting  due  to  a  material  weakness  for  the  fiscal  year  ended  December  31,  2015,
Deloitte’s audit reports on our consolidated financial statements as of December 31, 2015 and 2014 and for each of the years ended December 31, 2015, 2014
and  2013  did  not  contain  an  adverse  opinion  or  a  disclaimer  of  opinion  and  were  not  qualified  or  modified  as  to  uncertainty,  audit  scope  or  accounting
principles.

92

 
 
 
 
 
 
 
 
   
 
   
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
During each of the years ended December 31, 2015, 2014 and 2013 and the subsequent interim period through March 3, 2017, there were (i) no disagreements
between us and Deloitte on any matter of accounting principles or practices, financial statement disclosure, or auditing scope or procedure, any of which, if
not  resolved  to  Deloitte’s  satisfaction,  would  have  caused  Deloitte  to  make  reference  thereto  in  their  reports,  and  (ii)  no  “reportable  events”  requiring
disclosure pursuant to Item 16F(a)(1)(v) of the instructions to Form 20-F in connection with our annual report on Form 20-F.

We  provided  Deloitte  with  a  copy  of  the  disclosures  under  this  Item  16F  and  requested  from  Deloitte  a  letter  addressed  to  the  Securities  and  Exchange
Commission indicating whether it agrees with such disclosures. A copy of Deloitte’s letter dated April 30, 2019 is attached as Exhibit 16.1.

During each of the years ended December 31, 2015, 2014 and 2013 and the subsequent interim period through March 3, 2017, neither we nor anyone on
behalf  of  us  has  consulted  with  Marcum  Bernstein  &  Pinchuk  LLP  regarding  (i)  the  application  of  accounting  principles  to  a  specific  transaction,  either
completed or proposed, or the type of audit opinion that might be rendered on our consolidated financial statements, and neither a written report nor oral
advice  was  provided  to  us  that  Marcum  Bernstein  &  Pinchuk  LLP  concluded  was  an  important  factor  considered  by  us  in  reaching  a  decision  as  to  any
accounting, auditing, or financial reporting issue, (ii) any matter that was the subject of a disagreement pursuant to Item 16F(a)(1)(iv) of the instructions to
Form 20-F, or (iii) any reportable event pursuant to Item 16F(a)(1)(v) of the instructions to  Form 20-F.

ITEM 16G.

CORPORATE GOVERNANCE 

The Nasdaq Stock Market rules require each issuer to hold an annual meeting of shareholders no later than one year after the end of the issuer’s fiscal year
end. They also require each issuer to seek shareholder approval for any establishment of or material amendment to the issuer’s equity compensation plans,
including any amendment effecting a repricing of outstanding options or increasing the amount of shares authorized under such plans. However, the rules
permit foreign private issuers like us to follow “home country practice” in certain corporate governance matters.

Maples and Calder (Hong Kong) LLP, our Cayman Islands counsel, has provided a letter to the Nasdaq Stock Market certifying that under Cayman Islands
law, we are not required to hold annual shareholder meetings. We held annual meetings in 2013. No annual meeting was held in 2014, 2015, 2016, 2017 and
2018. We may hold additional annual shareholder meetings in the future if there are significant issues that require shareholder approval.

Maples and Calder (Hong Kong) LLP has also provided letters to the Nasdaq Stock Market certifying that under Cayman Islands law, we are not required to
seek  shareholder  approval  for  the  establishment  of  or  any  material  amendments  to  our  equity  compensation  plans.  In  2008,  we  followed  home  country
practice with respect to our 2007 Option Plan by amending it to permit repricings of options without seeking shareholder approval. In 2011, we followed
home country practice with respect to our 2011 Option Plan by establishing it without seeking shareholder approval.

We have relied on and intend to continue to rely on the above home country practices under Cayman Islands law. Other than the above, we have followed and
intend to continue to follow the applicable corporate governance standards under the rules and regulations of the Nasdaq Stock Market.

ITEM 16H.

MINE SAFETY DISCLOSURE 

Not applicable.

ITEM 17.

FINANCIAL STATEMENTS 

We have elected to provide financial statements pursuant to Item 18.

PART III

93

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ITEM 18.

FINANCIAL STATEMENTS 

The full text of our audited consolidated financial statements begins on page F-2 of this annual report.

ITEM 19.

EXHIBITS

Exhibit
No.

Description

1.1

1.2

2.1

2.2

2.3

4.1

4.2

4.3

4.4

4.5

4.6

4.7

  Amended  and  Restated  Memorandum  and  Articles  of  Association  (incorporated  by  reference  to  Exhibit  99.3  to  Form  6-K  (File  No.

001-33765) filed on December 10, 2009)

  Amendment to Amended and Restated Memorandum and Articles of Association approved by the annual general shareholders meeting

on July 18, 2013 (incorporated by reference to Exhibit 99.2 to Form 6-K (File No. 001-33765) filed on June 27, 2013)

  Registrant’s Specimen Certificate for Ordinary Shares (incorporated by reference to Exhibit 4.2 to Registration Statement on Form F-1

(File No. 333-146825), as amended, initially filed on October 19, 2007)

  Form  of  Amended  and  Restated  Deposit  Agreement  among  the  Company,  the  depositary  and  holder  of  the  American  Depositary
Receipts (incorporated by reference to Exhibit 99-a to Post-effective Amendment No. 1 to the Registration Statement on Form F-6 (File
No. 333- 146908), filed with the SEC on March 29, 2019)

  Amended and Restated Shareholders’ Agreement originally dated as of June 7, 2007, as amended and restated on September 27, 2007,
among the Company and Shareholders (incorporated by reference to Exhibit 4.4 to Registration Statement on Form F-1 (File No. 333-
146825), as amended, initially filed on October 19, 2007)

  Amended and Restated 2007 Share Incentive Plan (incorporated by reference to Exhibit 99.2 to Form 6-K filed on December 10, 2009)

2011 Share Incentive Plan (incorporated by reference to Exhibit 4.49 to Annual Report on Form 20-F filed on April 30, 2012)

2012 Share Incentive Plan. (incorporated by reference to Exhibit 4.3 to Registration Statement on Form S-8 (File No. 333-187442) filed
on March 22, 2013)

  Form  of  Employment  Agreement  between  the  Company  and  an  Executive  Officer  of  the  Registrant  (incorporated  by  reference  to

Exhibit 10.3 to Registration Statement on Form F-1 (File No. 333- 146825), as amended, initially filed on October 19, 2007)

  Form  of  Employment  Agreement  between  the  Company  and  an  Executive  Officer  of  the  Registrant  (incorporated  by  reference  to

Exhibit 10.3 to Registration Statement on Form F-1 (File No. 333- 146825), as amended, initially filed on October 19, 2007)

Investment Framework Agreement dated October 18, 2005, as amended on September 27, 2007, among Man Guo, Qing Xu and CDH
China Management Company Limited (incorporated by reference to Exhibit 10.4 to Registration Statement on Form F-1 (File No. 333-
146825), as amended, initially filed on October 19, 2007)

  English Translation of Business Cooperation Agreement dated June 14, 2007 between Beijing Shengshi Lianhe Advertising Co., Ltd.
(now  known  as  Beijing  Linghang  Shengshi  Advertising  Co.,  Ltd.)  and  AirTV  United  Media  &  Culture  Co.,  Ltd.  (incorporated  by
reference  to  Exhibit  10.9  to  Registration  Statement  on  Form  F-1  (File  No.  333-146825),  as  amended,  initially  filed  on  October  19,
2007)

94

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit
No.

4.8

4.9

4.10

4.11

4.12

4.13

4.14

4.15

Description

  English  Translation  of  Amended  Power  of  Attorneys  dated  November  28,  2008  from  each  of  the  shareholders  of  Beijing  Shengshi
Lianhe Advertising Co., Ltd. (now known as Beijing Linghang Shengshi Advertising Co., Ltd.) (incorporated by reference to Exhibit
4.11 to Annual Report on Form 20-F filed on April 28, 2009)  

  English  Translation  of  Amended  and  Restated  Technology  Development  Agreement  dated  June  14,  2007  between  AirMedia
Technology  (Beijing)  Co.,  Ltd.  and  Beijing  Shengshi  Lianhe  Advertising  Co.,  Ltd.  (now  known  as  Beijing  Linghang  Shengshi
Advertising Co., Ltd.) (incorporated by reference to Exhibit 10.12 to Registration Statement on Form F-1 (File No. 333- 146825), as
amended, initially filed on October 19, 2007)

  English Translation of Supplementary Agreement dated November 30, 2007 to the Amended and Restated Technology Development
Agreement dated June 14, 2007 between AirMedia Technology (Beijing) Co., Ltd. and Beijing Shengshi Lianhe Advertising Co., Ltd.
(now known as Beijing Linghang Shengshi Advertising Co., Ltd.) (incorporated by reference to Exhibit 10.1 to Annual Report on Form
20-F filed on April 30, 2008)

  English  Translation  of  Amended  and  Restated  Technology  Support  and  Service  Agreement  dated  June  14,  2007  between  AirMedia
Technology  (Beijing)  Co.,  Ltd.  and  Beijing  Shengshi  Lianhe  Advertising  Co.,  Ltd.  (now  known  as  Beijing  Linghang  Shengshi
Advertising Co., Ltd.) (incorporated by reference to Exhibit 10.13 to Registration Statement on Form F-1 (File No. 333- 146825), as
amended, initially filed on October 19, 2007)

  English  Translation  of  Supplementary  Agreement  dated  November  30,  2007  to  the  Amended  and  Restated  Technology  Support  and
Service Agreement dated June 14, 2007 between AirMedia Technology (Beijing) Co., Ltd. and Beijing Shengshi Lianhe Advertising
Co.,  Ltd.  (now  known  as  Beijing  Linghang  Shengshi  Advertising  Co.,  Ltd.)  (incorporated  by  reference  to  Exhibit  10.2  to  Annual
Report on Form 20-F filed on April 30, 2008)

  English Translation of Amended and Restated Equity Pledge Agreement dated June 14, 2007 among AirMedia Technology (Beijing)
Co.,  Ltd.,  Beijing  Shengshi  Lianhe  Advertising  Co.,  Ltd.  (now  known  as  Beijing  Linghang  Shengshi  Advertising  Co.,  Ltd.)  and  the
shareholders of Beijing Shengshi Lianhe Advertising Co., Ltd. (incorporated by reference to Exhibit 10.14 to Registration Statement on
Form F-1 (File No. 333-146825), as amended, initially filed on October 19, 2007)

  English Translation of Supplementary Agreement dated November 28, 2008 to the Amended and Restated Equity Pledge Agreement
dated June 14, 2007 among AirMedia Technology (Beijing) Co., Ltd., Beijing Shengshi Lianhe Advertising Co., Ltd. (now known as
Beijing Linghang Shengshi Advertising Co., Ltd.) and the shareholders of Beijing Shengshi Lianhe Advertising Co., Ltd. (incorporated
by reference to Exhibit 4.17 to Annual Report on Form 20-F filed on April 28, 2009)

  English Translation of Amended and Restated Call Option Agreement dated June 14, 2007 among AirMedia Technology (Beijing) Co.,
Ltd.,  Beijing  Shengshi  Lianhe  Advertising  Co.,  Ltd.  (now  known  as  Beijing  Linghang  Shengshi  Advertising  Co.,  Ltd.)  and  the
shareholders of Beijing Shengshi Lianhe Advertising Co., Ltd. (incorporated by reference to Exhibit 10.15 to Registration Statement on
Form F-1 (File No. 333-146825), as amended, initially filed on October 19, 2007)

95

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit
No.

4.16

4.17

4.18

4.19

4.20

4.21

4.22

4.23

Description

  English  Translation  of  Supplementary  Agreement  dated  November  28,  2008  to  the  Amended  and  Restated  Call  Option  Agreement
dated June 14, 2007 among AirMedia Technology (Beijing) Co., Ltd., Beijing Shengshi Lianhe Advertising Co., Ltd. (now known as
Beijing Linghang Shengshi Advertising Co., Ltd.) and the shareholders of Beijing Shengshi Lianhe Advertising Co., Ltd. (incorporated
by reference to Exhibit 4.19 to Annual Report on Form 20-F filed on April 28, 2009)  

  English  Translation  of  Amended  Power  of  Attorneys  dated  November  28,  2008  from  the  shareholders  of  Beijing  AirMedia  UC
Advertising Co., Ltd. (now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by reference to Exhibit 4.32 to
Annual Report on Form 20-F filed on April 28, 2009)  

  English  Translation  of  Technology  Development  Agreement  dated  June  14,  2007  between  AirMedia  Technology  (Beijing)  Co.,  Ltd.
and  Beijing  AirMedia  UC  Advertising  Co.,  Ltd.  (now  known  as  Beijing  AirMedia  Jiaming  Advertising  Co.,  Ltd.  )  (incorporated  by
reference to Exhibit 10.22 to Registration Statement on Form F-1 (File No. 333-146825), as amended, initially filed on October 19,
2007)

  English Translation of Supplementary Agreement dated November 30, 2007 to the Amended and Restated Technology Development
Agreement  dated  June  14,  2007  between  AirMedia  Technology  (Beijing)  Co.,  Ltd.  and  Beijing  AirMedia  UC  Advertising  Co.,  Ltd.
(now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by reference to Exhibit 10.5 to Annual Report on Form
20-F filed on April 30, 2008)

  English Translation of Technology Support and Service Agreement dated June 14, 2007 between AirMedia Technology (Beijing) Co.,
Ltd. and Beijing AirMedia UC Advertising Co., Ltd. (now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by
reference to Exhibit 10.23 to Registration Statement on Form F-1 (File No. 333- 146825), as amended, initially filed on October 19,
2007)

  English  Translation  of  Supplementary  Agreement  dated  November  30,  2007  to  the  Amended  and  Restated  Technology  Support  and
Service Agreement dated June 14, 2007 between AirMedia Technology (Beijing) Co., Ltd. and Beijing AirMedia UC Advertising Co.,
Ltd. (now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by reference to Exhibit 10.6 to Annual Report on
Form 20-F filed on April 30, 2008)

  English  Translation  of  Equity  Pledge  Agreement  dated  June  14,  2007  among  AirMedia  Technology  (Beijing)  Co.,  Ltd.,  Beijing
AirMedia  UC  Advertising  Co.,  Ltd.  and  the  shareholders  of  Beijing  AirMedia  UC  Advertising  Co.,  Ltd.  (now  known  as  Beijing
AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by reference to Exhibit 10.24 to Registration Statement on Form F-1 (File No.
333-146825), as amended, initially filed on October 19, 2007)

  English  Translation  of  Supplementary  Agreement  dated  November  28,  2008  to  the  Equity  Pledge  Agreement  dated  June  14,  2007
among AirMedia Technology (Beijing) Co., Ltd., Beijing AirMedia UC Advertising Co., Ltd. and the shareholders of Beijing AirMedia
UC Advertising Co., Ltd. (now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by reference to Exhibit 4.38
to Annual Report on Form 20-F filed on April 28, 2009)

96

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit
No.

4.24

4.25

4.26

4.27

4.28

4.29

4.30

4.31

4.32

4.33

Description

  English Translation of Call Option Agreement dated June 14, 2007 among AirMedia Technology (Beijing) Co., Ltd., Beijing AirMedia
UC  Advertising  Co.,  Ltd.  and  the  shareholders  of  Beijing  AirMedia  UC  Advertising  Co.,  Ltd.  (now  known  as  Beijing  AirMedia
Jiaming  Advertising  Co.,  Ltd.)  (incorporated  by  reference  to  Exhibit  10.25  to  Registration  Statement  on  Form  F-1  (File  No.  333-
146825), as amended, initially filed on October 19, 2007)

  English Translation of Supplementary Agreement dated November 28, 2008 to the Call Option Agreement dated June 14, 2007 among
AirMedia Technology (Beijing) Co., Ltd., Beijing AirMedia UC Advertising Co., Ltd. and the shareholders of Beijing AirMedia UC
Advertising Co., Ltd. (now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by reference to Exhibit 4.40 to
Annual Report on Form 20-F filed on April 28, 2009)

  English Translation of Supplementary Agreement No. 2 to Call Option Agreement dated May 27, 2010 among AirMedia Technology
(Beijing) Co., Ltd., Beijing AirMedia UC Advertising Co., Ltd. and the shareholders of Beijing AirMedia UC Advertising Co., Ltd.
(now known as Beijing AirMedia Jiaming Advertising Co., Ltd.) (incorporated by reference to Exhibit 4.45 to Annual Report on Form
20-F filed on May 28, 2010)  

  English  Translation  of  Supplementary  Agreement  dated  October  31,  2008  among  AirMedia  Technology  (Beijing)  Co.,  Ltd.  and  the
shareholders  of  Beijing  AirMedia  UC  Advertising  Co.,  Ltd.  (now  known  as  Beijing  AirMedia  Jiaming  Advertising  Co.,  Ltd.),
supplementing  the  original  Loan  Agreement  dated  January  1,  2007  (incorporated  by  reference  to  Exhibit  4.41  to  Annual  Report  on
Form 20-F filed on April 28, 2009)

  English  Translation  of  Supplementary  Agreement  No.  2  to  the  Equity  Pledge  Agreement  dated  May  27,  2010  among  AirMedia
Technology (Beijing) Co., Ltd., Beijing AirMedia UC Advertising Co., Ltd. and the shareholders of Beijing AirMedia UC Advertising
Co., Ltd. (now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) (incorporated by reference to Exhibit 4.46 to Annual Report
on Form 20-F filed on May 28, 2010)

  English  Translation  of  Power  of  Attorneys  dated  April  1,  2008  from  each  of  the  shareholders  of  Beijing  Yuehang  Digital  Media

Advertising Co., Ltd. (incorporated by reference to Exhibit 4.42 to Annual Report on Form 20-F filed on April 28, 2009)

  English Translation of Technology Development Agreement dated April 1, 2008 between AirMedia Technology (Beijing) Co., Ltd. and
Beijing Yuehang Digital Media Advertising Co., Ltd. (incorporated by reference to Exhibit 4.43 to Annual Report on Form 20-F filed
on April 28, 2009)

  English Translation of Technology Support and Service Agreement dated April 1, 2008 between AirMedia Technology (Beijing) Co.,
Ltd. and Beijing Yuehang Digital Media Advertising Co., Ltd. (incorporated by reference to Exhibit 4.44 to Annual Report on Form 20-
F filed on April 28, 2009)

  English Translation of Supplementary Agreement dated June 25, 2008 to the Technology Support and Service Agreement dated April 1,
2008  between  AirMedia  Technology  (Beijing)  Co.,  Ltd.  and  Beijing  Yuehang  Digital  Media  Advertising  Co.,  Ltd.  (incorporated  by
reference to Exhibit 4.45 to Annual Report on Form 20-F filed on April 28, 2009)

  English Translation of Equity Pledge Agreement dated April 1, 2008 among AirMedia Technology (Beijing) Co., Ltd., Beijing Yuehang
Digital  Media  Advertising  Co.,  Ltd.  and  the  shareholders  of  Beijing  Yuehang  Digital  Media  Advertising  Co.,  Ltd.  (incorporated  by
reference to Exhibit 4.46 to Annual Report on Form 20-F filed on April 28, 2009)

97

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit
No.

4.34

4.35

4.36

4.37

4.38

4.39

4.40

4.41

4.42

4.43

4.44

Description

  English Translation of Call Option Agreement dated April 1, 2008 among AirMedia Technology (Beijing) Co., Ltd., Beijing Yuehang
Digital  Media  Advertising  Co.,  Ltd.  and  the  shareholders  of  Beijing  Yuehang  Digital  Media  Advertising  Co.,  Ltd.  (incorporated  by
reference to Exhibit 4.47 to Annual Report on Form 20-F filed on April 28, 2009)

  English summary of Investment Agreement, dated May 12, 2013, by and among Elec-Tech International Co., Ltd., Beijing AirMedia
UC Advertising Co., Ltd. (now known as Beijing AirMedia Jiaming Advertising Co., Ltd. ) and Beijing Zhongshi Aoyou Advertising
Co., Ltd. (incorporated by reference to Exhibit 4.50 to Annual Report on Form 20-F filed on April 25, 2014)

  English summary of Cooperation Agreement for the Establishment of Advertising Company, dated May 2013, by and between Beijing
Shengshi Lianhe Advertising Co., Ltd. (now known as Beijing Linghang Shengshi Advertising Co., Ltd.), and Guangzhou Daozheng
Advertising Co., Ltd. (incorporated by reference to Exhibit 4.51 to Annual Report on Form 20-F filed on April 25, 2014)

  English  summary  of  Equity  Swap  Agreement,  dated  September  29,  2013,  by  and  between  Beijing  N-S  Digital  TV  Co.,  Ltd.  and

AirMedia Group Co., Ltd. (incorporated by reference to Exhibit 4.52 to Annual Report on Form 20-F filed on April 25, 2014)

  Agreement and Plan of Merger, dated as of September 29, 2015, by and among the Registrant, AirMedia Holdings Ltd. and AirMedia
Merger  Company  Limited  (incorporated  herein  by  reference  to  Exhibit  99.2  of  our  current  report  on  Form  6-K  filed  with  the
Commission on September 30, 2015).  

  English translation of Equity Interest Transfer Agreement in respect of AirMedia Group Co., Ltd., dated June 15, 2015, by and among
AirMedia  Group  Inc.,  AirMedia  Technology  (Beijing)  Co.,  Ltd,  Beijing  Linghang  Shengshi  Advertising  Co.,  Ltd.,  Man  Guo  and
Beijing Longde Wenchuang Investment Fund Management Company. (incorporated by reference to Exhibit 4.39 to Annual Report on
Form 20-F filed on May 16, 2016)

  English  translation  of  Supplement  Agreement  of  Equity  Transfer,  dated  November  30,  2015,  by  and  among  AirMedia  Group  Inc.,
AirMedia Technology (Beijing) Co., Ltd, Beijing Linghang Shengshi Advertising Co., Ltd., Man Guo and Beijing Longde Wenchuang
Investment Fund Management Company. (incorporated by reference to Exhibit 4.40 to Annual Report on Form 20-F filed on May 16,
2016)

  English  translation  of  Exclusive  Technology  Consulting  and  Service  Agreement,  dated  June  5,  2015,  by  and  between  AirMedia
Technology  (Beijing)  Co.,  Ltd.  and  AirMedia  Online  Network  Technology  Co.,  Ltd.  (incorporated  by  reference  to  Exhibit  4.41  to
Annual Report on Form 20-F filed on May 16, 2016)

  English translation of Technology Development Agreement, dated June 5, 2015, by and between AirMedia Technology (Beijing) Co.,
Ltd. and AirMedia Online Network Technology Co., Ltd. (incorporated by reference to Exhibit 4.42 to Annual Report on Form 20-F
filed on May 16, 2016)

  English translation of Technology Support and Service Agreement, dated June 5, 2015, by and between AirMedia Technology (Beijing)
Co., Ltd. and AirMedia Online Network Technology Co., Ltd. (incorporated by reference to Exhibit 4.43 to Annual Report on Form 20-
F filed on May 16, 2016)

  English  translation  of  Loan  Agreements,  dated  June  5,  2015,  by  and  between  AirMedia  Technology  (Beijing)  Co.,  Ltd.  and  each
shareholder of AirMedia Online Network Technology Co., Ltd. (except Yi Zhang) (incorporated by reference to Exhibit 4.44 to Annual
Report on Form 20-F filed on May 16, 2016)

98

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit
No.

4.45

4.46

4.47

4.48

4.49

4.50

4.51

4.52

4.53

Description

  English translation of Exclusive Call Option Agreement, dated June 5, 2015, by and between AirMedia Technology (Beijing) Co., Ltd.,
AirMedia Online Network Technology Co., Ltd. and each shareholder of AirMedia Online Network Technology Co., Ltd. (except Yi
Zhang) (incorporated by reference to Exhibit 4.45 to Annual Report on Form 20-F filed on May 16, 2016)

  English translation of Power of Attorney, dated June 5, 2015, by each shareholder of AirMedia Online Network Technology Co., Ltd.

(except Yi Zhang) (incorporated by reference to Exhibit 4.46 to Annual Report on Form 20-F filed on May 16, 2016)

  English  translation  of  Equity  Pledge  Agreements,  dated  June  5,  2015,  by  and  among  AirMedia  Technology  (Beijing)  Co.,  Ltd.,
AirMedia Online Network Technology Co., Ltd. and each shareholder of AirMedia Online Network Technology Co., Ltd. (except Yi
Zhang) (incorporated by reference to Exhibit 4.47 to Annual Report on Form 20-F filed on May 16, 2016)

  English  translation  of  Supplement  Agreement  in  respect  of  the  Related  Agreement  Arrangement  of  Beijing  Linghang  Shengshi
Advertising  Co.,  Ltd.,  dated  January  21,  2016,  by  and  among  AirMedia  Technology  (Beijing)  Co.,  Ltd.,  Man  Guo  and  Qing  Xu
(incorporated by reference to Exhibit 4.48 to Annual Report on Form 20-F filed on May 16, 2016)

  English  translation  of  Supplement  Agreement  in  respect  of  the  Related  Agreement  Arrangement  of  Beijing  AirMedia  Jiaming
Advertising  Co.,  Ltd.,  dated  January  21,  2016,  by  and  among  AirMedia  Technology  (Beijing)  Co.,  Ltd.,  Man  Guo  and  Qing  Xu
(incorporated by reference to Exhibit 4.49 to Annual Report on Form 20-F filed on May 16, 2016)

  English  translation  of  Supplement  Agreement  in  respect  of  the  Related  Agreement  Arrangement  of  AirMedia  Online  Network
Technology  Co.,  Ltd.,  dated  March  15,  2016,  by  and  among  AirMedia  Technology  (Beijing)  Co.,  Ltd.,  Man  Guo,  Qing  Xu  and  Tao
Hong (incorporated by reference to Exhibit 4.50 to Annual Report on Form 20-F filed on May 16, 2016)

  English  translation  of  Capital  Contribution  Agreement  for  the  Establishment  of  Unicom  AirNet  (Beijing)  Network  Co.  Ltd.  by  and
among AirMedia Online Network Technology Co., Ltd., Unicom Boardband Online Co., Ltd. and Chengdu Haite Kairong Aeronautical
Technology Co., Ltd. (incorporated by reference to Exhibit 4.51 to Annual Report on Form 20-F filed on June 28, 2017)

  English  translation  of  Memorandum  on  Subsequent  Performance  of  AirMedia  Group  Co.,  Ltd.  Equity  Transfer  Agreement  and
Supplementary  Agreement,  dated  March  28,  2018,  by  and  among  AirMedia  Group  Inc.,  AirMedia  Technology  (Beijing)  Co.,  Ltd.,
Beijing Linghang Shengshi Advertising Co., Ltd., Mr. Herman Man Guo, Mr. Qing Xu, Beijing Longde Wenchuang Investment Fund
Management Co., Ltd., Beijing Cultural Center Construction and Development Fund (Limited Partnership) and AirMedia Group Co.,
Ltd. (incorporated by reference to Exhibit 99.1 to Form 6-K (File No. 001-33765) filed on March 29, 2018)

  English  translation  of  Supplementary  Agreement  for  the  Memorandum  Regarding  Continued  Implementation  of  the  Agreement  on
Equity  Transfer  of  AirMedia  Group  Co.,  Ltd.  and  its  Supplementary  Agreement,  dated  August  23,  2018,  by  and  among  AirMedia
Group Inc., Hangmei United Media Technology (Beijing) Co., Ltd., Beijing Hangmei Shengshi Advertising Co., Ltd., Mr. Herman Man
Guo, Mr. Qing Xu, Beijing Longde Wenchuang Investment Fund Management Co., Ltd., Beijing Cultural Center Development Fund
(Limited Partnership) and AirMedia Group Co., Ltd. (incorporated by reference to Exhibit 4.53 to Annual Report on Form 20-F filed
on October 17, 2018)

99

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit
No.

4.54

4.55*

8.1*

11.1

12.1*

12.2*

13.1**

13.2**

15.1*

15.2*

15.3*

16.1*

Description

  English  translation  of  equity  transfer  agreement  in  respect  of  Airmedia  Group  Co.,  Ltd.,  dated  November  5,  2018,  by  and  among
Beijing  Linghang  Shengshi  Advertising  Co.,Ltd.,  Guo  Man,  Xu  Qing,  and  Jiangsu  Hongzhou  Investment  Co.,  Ltd.  (incorporated  by
reference to Exhibit 99.2 to Form 6-K (File No. 001-33765) filed on November 7, 2018)

  English  translation  of  Supplementary  Agreement  for  the  Memorandum  Regarding  Continued  Implementation  of  the  Agreement  on
Equity Transfer of AirMedia Group Co., Ltd. and its Supplementary Agreement, dated November 2018, by and among AirMedia Group
Inc., Hangmei United Media Technology (Beijing) Co., Ltd., Beijing Hangmei Shengshi Advertising Co., Ltd., Mr. Herman Man Guo,
Mr.  Qing  Xu,  Beijing  Longde  Wenchuang  Investment  Fund  Management  Co.,  Ltd.,  Beijing  Cultural  Center  Development  Fund
(Limited Partnership) and AirMedia Group Co., Ltd.

  List of the Registrant’s subsidiaries 

  Code of Business Conduct and Ethics of the Registrant (incorporated by reference to Exhibit 99.1 to Registration Statement on Form F-

1 (File No. 333-146825), as amended, initially filed on October 19, 2007)

  Certification by Principal Executive Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

  Certification by Principal Financial Officer Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

  Certifications by Principal Executive Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

  Certifications by Principal Financial Officer Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

  Consent of Marcum Bernstein & Pinchuk LLP

  Consent of Commerce & Finance Law Offices

  Consent of Maples and Calder (Hong Kong) LLP

  Letter from Deloitte Touche Tohmatsu Certified Public Accountants LLP to the Securities and Exchange Commission

101.INS*

  XBRL Instance Document

101.SCH*

  XBRL Taxonomy Extension Schema Document

101.CAL*

  XBRL Taxonomy Extension Calculation Linkbase Document

101.DEF*

  XBRL Taxonomy Extension Definition Linkbase Document

101.LAB*

  XBRL Taxonomy Extension Label Linkbase Document

101.PRE*

  XBRL Taxonomy Extension Presentation Linkbase Document 

*

Filed herewith

** Furnished with this annual report on Form 20-F

100

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The registrant hereby certifies that it meets all of the requirements for filing on Form 20-F and that it has duly caused and authorized the undersigned to sign
this annual report on its behalf.

Date: April 30, 2019

AIRMEDIA GROUP INC.

SIGNATURE

/s/ Herman Man Guo

Herman Man Guo
Chairman and Chief Executive Officer

101

 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

INDEX TO CONSOLIDATED FINANCIAL STATEMENTS

CONTENTS

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

CONSOLIDATED BALANCE SHEETS AS OF DECEMBER 31, 2017 AND 2018

CONSOLIDATED STATEMENTS OF OPERATIONS FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018

CONSOLIDATED STATEMENTS OF COMPREHENSIVE LOSS FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018

CONSOLIDATED STATEMENTS OF CHANGES IN EQUITY FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018

CONSOLIDATED STATEMENTS OF CASH FLOWS FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

ADDITIONAL INFORMATION-FINANCIAL STATEMENT SCHEDULE I

PAGE(S)

F-1

F-2

F-4

F-5

F-6

F-7

F-8~F-58

F-59~F-64

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Shareholders and Board of Directors of
AirMedia Group Inc.

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets of AirMedia Group Inc. (the “Company”) as of December 31, 2018 and 2017, the related
consolidated statements of operations, comprehensive loss, changes in equity and cash flows for each of the three years in the period ended December 31,
2018,  and  the  related  notes  (collectively  referred  to  as  the  “financial  statements”).  In  our  opinion,  the  financial  statements  present  fairly,  in  all  material
respects, the financial position of the Company as of December 31, 2018 and 2017, and the results of its operations and its cash flows for each of the three
years in the period ended December 31, 2018, in conformity with accounting principles generally accepted in the United States of America.

Explanatory Paragraph – Going Concern

The  accompanying  consolidated  financial  statements  have  been  prepared  assuming  that  the  Company  will  continue  as  a  going  concern.  As  more  fully
described in Note 2(b), the Company has a significant working capital deficiency, has incurred significant losses and needs to raise additional funds to meet
its obligations and sustain its operations. These conditions raise substantial doubt about the Company's ability to continue as a going concern. Management's
plans in regard to these matters are also described in Note 2(b). The consolidated financial statements do not include any adjustments that might result from
the outcome of this uncertainty.

Basis for Opinion

These  financial  statements  are  the  responsibility  of  the  Company's  management.  Our  responsibility  is  to  express  an  opinion  on  the  Company's  financial
statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) ("PCAOB")
and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of
the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audits to obtain reasonable
assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. The Company is not required to have, nor
were  we  engaged  to  perform,  an  audit  of  its  internal  control  over  financial  reporting.  As  part  of  our  audits  we  are  required  to  obtain  an  understanding  of
internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control over financial
reporting. Accordingly, we express no such opinion.

Our  audits  included  performing  procedures  to  assess  the  risks  of  material  misstatement  of  the  financial  statements,  whether  due  to  error  or  fraud,  and
performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the
financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating
the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

/s/ Marcum Bernstein & Pinchuk LLP

Marcum Bernstein & Pinchuk LLP

We have served as the Company’s auditor since 2017.

New York, New York
April 30, 2019

F-1 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

CONSOLIDATED BALANCE SHEETS
(In U.S. dollars in thousands, except share and per share data)

Assets
Current assets:

Cash and cash equivalents
Restricted cash
Accounts receivable, net
Prepaid concession fees
Other current assets, net
Amount due from related parties

Total current assets

Property and equipment, net
Prepaid equipment costs
Long-term investments
Long-term deposits
Other non-current assets

TOTAL ASSETS

Liabilities
Current liabilities:
Short-term loan
Accounts payable
Accrued expenses and other current liabilities
Deferred revenue
Consideration received from buyer
Payable of earnout commitment
Income tax payable
Total current liabilities
Non-current liabilities:

Long-term loan
Other non-current liabilities
Provision for earnout commitment

Total liabilities

F-2

  $

  $

  $

As of December 31,

2017

2018

15,355    $
3,117     
10,980     
7,064     
59,825     
2,251     
98,592     

15,442     
290     
102,434     
6,039     
2,205     
225,002    $

-    $
48,545     
12,236     
1,337     
-     
-     
13,677     
75,795     

-     
398     
25,130     
101,323     

15,536 
3 
7,938 
1,813 
41,057 
18 
66,365 

13,466 
2,364 
46,271 
1,350 
- 
129,816 

6,109 
39,304 
9,758 
1,995 
21,817 
22,188 
11,483 
112,654 

2,763 
- 
- 
115,417 

 
 
 
 
 
 
 
 
 
   
 
   
      
  
   
      
  
   
   
   
   
   
   
 
   
      
  
   
   
   
   
   
   
      
  
   
      
  
   
   
   
   
   
   
   
   
      
  
   
   
   
   
 
 
 
AIRMEDIA GROUP INC.

CONSOLIDATED BALANCE SHEETS - CONTINUED
(I n U.S. dollars in thousands, except share and per share data)

Equity

Ordinary shares ($0.001 par value; 900,000,000 shares authorized in 2017 and 2018; 127,662,057 shares and

127,697,055 shares issued as of December 31, 2017 and 2018, respectively; 125,629,779 shares and 125,664,777
shares outstanding as of December 31, 2017 and 2018, respectively)

Additional paid-in capital
Treasury stock (2,032,278 and 2,032,278 shares as of December 31, 2017 and 2018, respectively)
Accumulated deficits
Accumulated other comprehensive income
Total AirMedia Group Inc.'s shareholders' equity

Non-controlling interests
Total equity

TOTAL LIABILITIES AND EQUITY

As of December 31,

2017

2018

128     
286,739     
(2,351)    
(172,318)    
35,451     
147,649     

(23,970)    
123,679     

128 
284,726 
(2,351)
(262,415)
31,311 
51,399 

(37,000)
14,399 

  $

225,002    $

129,816 

The accompanying notes are an integral part of these consolidated financial statements.

F-3

 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
 
 
   
      
  
 
   
      
  
   
   
   
   
   
   
 
   
      
  
   
   
 
   
      
  
 
 
 
 
AIRMEDIA GROUP INC.

CONSOLIDATED STATEMENTS OF OPERATIONS
(In U.S. dollars in thousands, except share and per share data)

For the years ended December 31,
2017

2016

2018

Revenues
Business tax and other sales tax
Net revenues
Less: Cost of revenues
Gross loss

Operating expenses:

Selling and marketing
General and administrative
Impairment of fixed assets, prepaid equipment cost and intangible assets

Total operating expenses

Loss from operations
Other income (expenses):

Interest income (expense), net
Loss from and impairment on long-term investments
Other income, net

Total other income (expense)

Loss before income tax
Income tax expense
Net loss
Less: Net loss attributable to non-controlling interests
Net loss attributable to AirMedia Group Inc.'s shareholders

Net loss per ordinary share

Basic and diluted

Net loss per ADS

Basic and diluted.

  $

  $

  $

  $

16,597    $
(84)    
16,513     
49,042     
(32,529)    

12,056     
44,401     
826     
57,283     

24,328    $
(569)    
23,759     
58,967     
(35,208)    

12,747     
63,507     
67,342     
143,596     

24,776 
(230)
24,546 
32,630 
(8,084)

7,492 
32,612 
564 
40,668 

(89,812)    

(178,804)    

(48,752)

843     
(33)    
4,243     
5,053     

(84,759)    
4,483     
(89,242)    
(23,617)    
(65,625)   $

2,645     
(2,603)    
214     
256     

(178,548)    
633     
(179,181)    
(22,705)    
(156,476)   $

(106)
(52,337)
7,926 
(44,517)

(93,269)
150 
(93,419)
(3,322)
(90,097)

(0.52)   $

(1.25)   $

(0.72)

(5.24)   $

(12.46)   $

(7.17)

Weighted average shares used in calculating net loss per ordinary share

Basic and diluted

Weighted average ADS used in calculating net loss per ADS

Basic and diluted

125,277,056     

125,629,779     

125,653,175 

12,527,706     

12,562,978     

12,565,318 

The accompanying notes are an integral part of these consolidated financial statements. 

F-4

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
   
 
   
 
 
   
   
   
   
 
   
      
      
  
   
      
      
  
   
   
   
   
 
   
      
      
  
   
   
      
      
  
   
   
   
   
 
   
      
      
  
   
   
   
   
 
   
      
      
  
   
      
      
  
 
   
      
      
  
   
      
      
  
 
   
      
      
  
   
      
      
  
   
 
   
      
      
  
   
      
      
  
   
 
 
 
 
AIRMEDIA GROUP INC.

CONSOLIDATED STATEMENTS OF COMPREHENSIVE LOSS
(In U.S. dollars in thousands)

For the years ended December 31,
2017

2016

2018

Net loss
Other comprehensive loss, net of tax of nil:
Foreign currency translation adjustment

Comprehensive loss
Less: comprehensive loss attributable to non-controlling interests

  $

(89,242)   $

(179,181)   $

(93,419)

(24,140)    

35,716     

(2,974)

(113,382)    
(24,537)    

(143,465)    
(22,732)    

(96,393)
(2,156)

Comprehensive loss attributable to AirMedia Group Inc.'s shareholders

  $

(88,845)   $

(120,733)   $

(94,237)

The accompanying notes are an integral part of these consolidated financial statements.

F-5

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
   
 
   
 
 
   
      
      
  
   
 
   
      
      
  
   
   
 
   
      
      
  
 
 
 
 
AIRMEDIA GROUP INC.

CONSOLIDATED STATEMENTS OF CHANGES IN EQUITY
(In U.S. dollars in thousands, except share and per share data)

Ordinary shares

Shares

    Amount    

    Additional   
paid-in
capital

Treasury

stock    

Accumulated
deficits

Accumulated
other
comprehensive
income (loss)    

Total
AirMedia Group
Inc.'s
shareholders'
equity

Non-
controlling
interests    

Total
Equity  

Balance as of January 1, 2016
Stock option exercised
Share-based compensation
Foreign currency translation adjustment
Net loss
Acquisition of equity interests from non-controlling

shareholders

Capital contribution from non-controlling interests

Balance as of December 31, 2016
Share-based compensation
Capital contribution from non-controlling interests
Acquisition of equity interests from non-controlling

shareholders

Disposal of Hainan Jinhui
Foreign currency translation adjustment
Net loss

Balance as of December 31, 2017
Share issued to Ascent Investor Relations LLC
Share-based compensation
Capital withdraw from non-controlling interests
Subscription receivables from NCI
Foreign currency translation adjustment
Net loss
Acquisition of additional equity interest in a

subsidiary from the non-controlling interest

Balance as of December 31, 2018

    124,395,645     
1,234,134     
-     
-     
-     

128     
-     
-     
-     
-     

317,414     
-     
773     
-     
-     

(3,778)    
1,427     
-     
-     
-     

49,876     
(93)    
-     
-     
(65,625)    

-     
-     

-     
-     

(34,570)    
3,477     

-     
-     

-     
-     

    125,629,779     
-     
-     

128     
-     
-     

287,094     
343     
716     

(2,351)    
-     
-     

-     
-     
-     
-     

-     
-     
-     
-     

(1,414)    
-     
-     
-     

-     
-     
-     
-     

(15,842)    
-     
-     

-     
-     
-     
(156,476)    

22,928     
-     
-     
(23,220)    
-     

-     
-     

(292)    
-     
-     

-     
-     
35,743     
-     

    125,629,779    $
34,998     

-     

-     
-     

128    $ 286,739    $ (2,351)   $
18     
0.03     
45     
(1,131)    

-     

-     

(172,318)   $

35,451    $

-     

-     

-     
-     

-     
-     

-     
-     

-     
(90,097)    

(4,140)    
-     

    125,664,777    $

(945)    
128    $ 284,726    $ (2,351)   $

(262,415)   $

31,311    $

386,568     
1,334     
773     
(23,220)    
(65,625)    

11,065      397,633 
1,334 
773 
(24,140)
(89,242)

-     
-     
(920)    
(23,617)    

(34,570)    
3,477     

3,614     
7,718     

(30,956)
11,195 

268,737     
343     
716     

(2,140)     266,597 
343 
1,863 

-     
1,147     

(1,414)    
-     
35,743     
(156,476)    

-     
(245)    
(27)    

(1,414)
(245)
35,716 
(22,705)     (179,181)

147,649    $
18     
45     
(1,131)    

(4,140)    
(90,097)    

(23,970)   $ 123,679 
18 
45 
(10,186)
(1,969)
(2,974)
(93,419)

(9,055)    
(1,969)    
1,166     
(3,322)    

(945)    
51,399    $

150     
(37,000)   $

(795)
14,399 

The accompanying notes are an integral part of these consolidated financial statements.

F-6

 
 
 
 
 
 
 
   
 
   
 
   
 
   
 
   
 
   
   
 
   
 
 
 
 
 
   
 
   
   
   
   
 
 
 
 
   
   
   
 
 
    
    
    
    
    
    
    
    
  
   
   
   
   
   
   
 
   
      
      
      
      
      
      
      
      
  
   
   
   
   
   
   
 
   
      
      
      
      
      
      
      
      
  
   
      
      
      
      
   
      
      
      
      
      
      
   
   
      
      
      
      
      
      
      
   
   
   
      
      
      
      
      
 
 
 
 
AIRMEDIA GROUP INC.

CONSOLIDATED STATEMENTS OF CASH FLOWS
(In U.S. dollars in thousands)

For the years ended December 31,
2017

2016

2018

CASH FLOWS FROM OPERATING ACTIVITIES:

Net loss

  $

(89,242)   $

(179,181)   $

(93,419)

Adjustments to reconcile net loss to net cash used in operating activities:

Bad debt provisions
Depreciation and amortization
Impairment of fixed assets, prepaid equipment cost and intangible assets
Share-based compensation
Loss and impairment on long-term investments
Loss on disposal of property and equipment
Impairment loss on inventory
Gain on fair value change of earn-out provision
Other income on concession payable waived
Write off of long-term deposit not refundable
Deferred tax valuation allowance

Changes in assets and liabilities

Accounts receivable
Prepaid concession fees
Other current assets
Long-term deposits
Other non-current assets
Amount due from related parties
Accounts payable
Accrued expenses and other current liabilities
Deferred revenue
Amount due to related parties
Income tax payable
Other noncurrent liabilities
Net cash used in operating activities

CASH FLOWS FROM INVESTING ACTIVITIES:

Purchase of property and equipment
Consideration receivable
Net amount received upon settlement of short-term investment
Acquisition of equity interests from non-controlling shareholders
Proceeds from disposal of equity investment
Loan to third parties
Collection of loan to third parties
Purchase of long-term investment

Net cash provided by (used in) investing activities

CASH FLOWS FROM FINANCING ACTIVITIES:

Cash received from short-term loan
Cash received from long-term loan
Capital contribution from non-controlling interest
Capital withdraw by non-controlling shareholder
Proceeds from options exercised

Net cash provided by financing activities

12,697     
12,971     
826     
773     
33     
22     
-     
-     
-     
-     
4,328     

(3,250)    
(3,043)    
(5,369)    
(1,962)    
(781)    
1,813     
6,730     
2,030     
517     
(15,023)    
(27,377)    
(303)    
(103,610)    

(21,558)    
195,915     
3,617     
(32,838)    
3,014     
(17,249)    
156     
(475)    
130,582     

-     
-     
9,796     
-     
1,334     
11,130     

37,255     
12,048     
67,342     
343     
2,603     
417     
-     
-     
-     
-     
-     

(1,874)    
1,656     
(821)    
789     
1,304     
(1,310)    
4,491     
(920)    
(525)    
-     
(1,712)    
(475)    
(58,570)    

(7,170)    
-     
-     
(1,414)    
1,502     
(29,825)    
7,190     
(17,449)    
(47,166)    

-     
-     
874     
-     
-     
874     

11,912 
1,560 
564 
45 
52,337 
- 
657 
(1,653)
(12,318)
359 
- 

1,361 
5,056 
4,541 
4,171 
1,210 
934 
7,751 
(3,693)
757 
- 
(1,515)
(391)
(19,774)

(3,616)
- 
- 
(302)
22,640 
- 
1,374 
- 
20,096 

6,339 
2,868 
- 
(10,902)
- 
(1,695)

Effect of exchange rate changes

(7,515)    

5,787     

(1,560)

Net increase (decrease) in cash, cash equivalents and restricted cash
Cash, cash equivalents and restricted cash, at beginning of year
Cash, cash equivalents and restricted cash, at end of year

 SUPPLEMENTAL DISCLOSURE OF CASH FLOW INFORMATION:

Income tax paid
Interests paid
Fair value of property, equipment and other assets acquired in exchange of advertising

services rendered and subsidiary's equity transferred

SUPPLEMENTAL DISCLOSURE OF NON-CASH ACTIVITIES:

Payable for purchase of property and equipment

30,587     
86,960     
117,547    $

(99,075)    
117,547     
18,472    $

27,712    $
-    $

1,601    $
-    $

541    $

169    $

(2,933)
18,472 
15,539 

1,665 
2,443 

- 

-    $

3,569    $

103 

  $

  $
  $

  $

  $

 
 
 
 
 
 
 
 
 
   
   
 
   
      
      
  
 
   
      
      
  
   
      
      
  
   
   
   
   
   
   
   
   
   
   
   
 
   
      
      
  
   
      
      
  
   
   
   
   
   
   
   
   
   
   
   
   
   
 
   
      
      
  
   
      
      
  
   
   
   
   
   
   
   
   
   
 
   
      
      
  
   
      
      
  
   
   
   
   
   
   
 
   
      
      
  
   
 
   
      
      
  
   
   
 
   
      
      
  
   
      
      
  
 
   
      
      
  
   
      
      
  
Payable of acquisition of non-controlling interests
Receivable of capital contribution from non-controlling interest
Payable of capital withdraw from non-controlling interest

  $
  $
  $

1,882    $
1,399    $
-    $

-    $
989    $
-    $

524 
- 
758 

The following table provides a reconciliation of cash, cash equivalents, and restricted cash reported within the consolidated balance sheets that sum to the
total of the same such amounts shown in the consolidated statements of cash flows:

Cash and cash equivalents
Restricted cash
Total cash, cash equivalents and restricted cash

2016

As of December 31,
2017

2018

  $

  $

117,547    $
-     
117,547    $

15,355    $
3,117     
18,472    $

15,536 
3 
15,539 

The accompanying notes are an integral part of these consolidated financial statements.

F-7

 
 
 
 
 
 
 
   
   
 
   
  
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES

Introduction of the Group

AirMedia Group Inc. ("AirMedia" or the "Company") was incorporated in the Cayman Islands on April 12, 2007.

AirMedia, its subsidiaries, its variable interest entities ("VIEs") and VIEs' subsidiaries (collectively the "Group") operate its out-of-home advertising
network, primarily air travel advertising network, in the People's Republic of China (the "PRC").

The Group provides advertising time slots in the form of TV-attached digital frames, digital TV screens in airports, digital TV screens on airplanes,
and  media  contents  display  in  air  travel.  Collaborating  with  our  partners,  AirMedia  serves  airline  travelers  with  interactive  entertainment  and  a
coverage of breaking news, and furnishes corporate clients with advertisements tailored to the perceptions of the travelers.

The Group started gas station media network and explored the on train and long-haul bus Wi-Fi business in 2009 and 2015, respectively. The Group
obtained concession rights to develop and operate an outdoor advertising network in Sinopec gas stations throughout China to play advertisements
on outdoor advertising platforms such as LED screens, billboards and light boxes at Sinopec gas stations and several concession rights from railway
administration  bureaus,  long-haul  bus  operators  in  China  to  install  and  operate  our  Wi-Fi  systems  to  provide  Wi-Fi  connections  to  passengers  to
improve travelers’ experience. In view of the underperformance of recent years ascribed to the wide spread of affordable 4G or 5G technology, to
achieve the resources realignment for the focused development of the in-flight media and connectivity business, the Group ceased our operations of
Wi-Fi  service  on  long-haul  buses  and  our  gas  station  media  services,  and  scaled  down  operations  in  providing  Wi-Fi  services  on  trains  in  2018.
These  disposals  do  not  represent  a  strategic  shift  on  our  advertising  business  which  have  no  major  effect  on  the  Group’s  results  of  operations
respectively.  Accordingly,  assets  and  liabilities,  revenues  and  expenses,  and  cash  flows  related  to  the  disposed  entities  is  not  required  to  be
reclassified in the accompanying consolidated financial statements as discontinued operations for all periods presented.

F-8

 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

Introduction of the Group - continued

As of issuance date of this report, details of the Company's subsidiaries, VIEs and VIEs' subsidiaries are as follows:

Name

Intermediate Holding Company:

Date of
incorporation/
acquisition

Place of
incorporation

Percentage
of legal
ownership

Broad Cosmos Enterprises Ltd. (“Broad Cosmos”)

June 26, 2006

British Virgin Islands ("BVI")

Air Net International Limited (Formerly AirMedia International Limited) ("Air Net

International")

Air Net (China) Limited (Fomerly AirMedia (China) Limited) ("AN China")

July 14, 2007

August 5, 2005

BVI

Hong Kong

Subsidiaries:

Yuehang Chuangyi Technology (Beijing) Co., Ltd. (Formerly AirMedia Technology

(Beijing) Co., Ltd.) ("Chuangyi Technology")

September 19, 2005

Shenzhen Yuehang Information Technology Co., Ltd. (Formerly Shenzhen AirMedia

Information Technology Co., Ltd.) ("Shenzhen Yuehang")

June 6, 2006

Xi'an Shengshi Dinghong Information Technology Co., Ltd. (Formerly Xi'an AirMedia

Chuangyi Technology Co., Ltd.) ("Xi'an Shengshi")

December 31, 2007

VIEs:

Beijing Linghang Shengshi Advertising Co., Ltd. (Formerly Beijing AirMedia Shengshi

Advertising Co., Ltd.) ("Linghang Shengshi ")

Wangfan Tianxia Network Technology Co., Ltd.(“Iwanfan”)

Beijing Yuehang Digital Media Advertising Co., Ltd. ("Beijing Yuehang")

AirMedia Online Network Technology Group Co., Ltd. (Formerly AirMedia Online

Network Technology Co., Ltd.) ("AM Online")

August 7, 2005

May 6, 2016

January 16, 2008

April 30, 2015

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

100%

100%

100%

100%

100%

100%

N/A 

N/A 

N/A 

N/A 

F-9

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
  
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
 
 
   
  
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
 
 
   
  
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
   
 
 
 
 
 
   
  
 
 
   
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

Introduction of the Group - continued

Name

VIEs' subsidiaries:

Date of
incorporation/
acquisition

Place of
incorporation

Percentage
of legal
ownership

Beijing Airnet Pictures Co., Ltd. (Formerly Beijing AirMedia Film & TV Culture Co., Ltd.)

("Airnet Pictures")

Beijing Zhihe Xianglong Advertising Co., Ltd. (Formerly Flying Dragon Media

Advertising Co., Ltd.) ("Flying Dragon")

Wenzhou Yuehang Advertising Co., Ltd. (Formerly Wenzhou AirMedia Advertising Co.,

Ltd.) ("Wenzhou Yuehang")

Beijing Dongding Gongyi Advertising Co., Ltd. ("Dongding")

Beijing GreatView Media Advertising Co., Ltd. (Formerly Beijing Weimei Shengjing

Media Advertising Co., Ltd.) ("GreatView Media")

Guangzhou Meizheng Online Network Technology Co., Ltd. (Formerly Guangzhou

Meizheng Advertising Co., Ltd.) ("Guangzhou Meizheng")

September 13, 2007

August 1, 2008

October 17, 2008

February 1, 2010

April 28, 2011

May 17, 2013

Beijing Yuehang Tianyi Electronic Information Technology Co., Ltd. (Formerly Beijing

AirMedia Tianyi Information Technology Co., Ltd.) ("Yuehang Tianyi")

September 25, 2013

Wangfan Linghang Mobile Network Technology Co., Ltd. (Formerly AirMedia Mobile

Network Technology Co., Ltd. ("Linghang")

Guangzhou Meizheng Information Technology Co., Ltd. ("Guangzhou Tech")

AirMedia Henglong Mobile Network Technology Co., Ltd. ("AMHL Mobile")

April 23, 2015

June 18, 2015

April 27, 2015

Beijing Wangfan Jiaming Pictures Co., Ltd. (Formerly Beijing AirMedia Jiaming Film &

TV Culture Co., Ltd.) ("Wangfan Jiaming")

December 31, 2015

Meizheng Network Information Technology Co., Ltd. (“Meizheng Network”)

August 8, 2016

Beijing Wangfan Jiaming Advertising Co.,Ltd. (Formerly Beijing AirMedia Jiaming

Advertising Co., Ltd.) ("Jiaming Advertising")  

January 1, 2007

Shandong Airmedia Cheweishi Network Technology Co., Ltd. (Formerly Shandong

Airmedia Car Safety Technology Co.,Ltd.) (“Shangdong Cheweishi”)

Dingsheng Ruizhi (Beiing) Investment Consulting Co., Ltd. (“Dingsheng Ruizhi”)

Wangfan Tongda Culture Development (Beijing) Co., Ltd. (“Tongda Culture”)

Yuehang Zhongying E-commerce Co., Ltd. (“Zhongying”)

Beijing Airport United Culture Media Co., Ltd. (“Airport United”)

July 21, 2016

May 25, 2016

May 11, 2018

May 17, 2018

June 19, 2018

F-10

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

the PRC

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

The VIE arrangements

Chinese regulations currently limit foreign ownership of companies that provide advertising services, including out-of-home television advertising
services. Since December 30, 2005, foreign investors have been permitted to own directly 100% interest in PRC advertising companies if the foreign
investor has at least three years of direct operations of advertising business outside of the PRC.

One  of  the  Company's  subsidiary, AN  China,  the  100%  shareholder  of  Chuangyi  Technology,  Shenzhen  Yuehang,  and  Xi’an  Shengshi,  has  been
engaged in the advertising business in Hong Kong since September 2008.

The  Group  conducts  substantially  all  of  its  activities  through  VIEs,  i.e.  Linghang  Shengshi,  Beijing  Yuehang  and  AM  Online,  and  the  VIEs'
subsidiaries. The VIEs have entered into the following series of agreements with Chuangyi Technology:

·

Technology support and service agreement: Chuangyi Technology provides exclusive technology support and consulting services to
the VIEs and in return, the VIEs are required to pay Chuangyi Technology service fees. The VIEs pay to Chuangyi Technology annual
service fees in the amount that guarantee that the VIEs can achieve, after deducting such service fees payable to Chuangyi Technology,
a net cost-plus rate of no less than 0.5% in the case of Linghang Shengshi, and Jiaming Advertising, or 1.0% in the case of Beijing
Yuehang, which final rate should be determined by Chuangyi Technology. The "net cost-plus rate" refers to the operating profit as a
percentage of total costs and expenses of a certain entity. The technology support and service fees for each given year payable by AM
Online to Chuangyi Technology under AM Online’s technology support and service agreement shall be determined by AM Online and
Chuangyi Technology at the first month of such year taking into account several factors. Those factors include the credential of the
team of Chuangyi Technology that provides services to AM Online, the number of service hours, the nature and value of the services
provided  by  Chuangyi  Technology,  the  extent  to  which  Chuangyi  Technology  provides  patent  or  other  license  to  AM  Online  in  its
provision of technology support and service and the correlation between AM Online’s results of operations and the technology support
and service provided by Chuangyi Technology. In the event Chuangyi Technology finds it necessary to make subsequent adjustment to
the  amount  of  fees,  AM  Online  shall  negotiate  in  good  faith  with  Chuangyi  Technology  to  determine  the  new  fee.  The  technology
support and service agreements are effective for ten years and such term is automatically renewed upon its expiry unless either party
informs the other party of its intention of no extension at least twenty days prior to the expiration of the agreements.

F-11

 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

The VIE arrangements - continued

·

·

Technology  development  agreement:  VIEs  exclusively  engaged  Chuangyi  Technology  to  provide  technology  development  services.
Chuangyi Technology owns the intellectual property rights developed in the performance of these agreements. Except for AM Online,
the VIEs pay to Chuangyi Technology annual service fees in the amount that guarantee that the VIEs can achieve, after deducting such
service fees payable to Chuangyi Technology, a net cost-plus rate of no less than 0.5% in the case of Linghang Shengshi, and Jiaming
Advertising, which final rate should be determined by Chuangyi Technology. It is at Chuangyi Technology's sole discretion that the rate
and amount of fees ultimately charged the VIEs under these agreements are determined. The "net cost-plus rate" refers to the operating
profit as a percentage of total costs and expenses of a certain entity. The technology development fees for each given year payable by
AM Online to Chuangyi Technology under AM Online’s technology development agreement shall be determined by AM Online and
Chuangyi Technology at the first month of such year taking into account several factors. Those factors include the credential of the
team of Chuangyi Technology that provides services to AM Online, the number of service hours, the nature and value of the services
provided  by  Chuangyi  Technology,  the  extent  to  which  Chuangyi  Technology  provides  patent  or  other  license  to  AM  Online  in  its
provision  of  technology  development  service  and  the  correlation  between  AM  Online’s  results  of  operations  and  the  technology
development  service  provided  by  Chuangyi  Technology.  In  the  event  Chuangyi  Technology  finds  it  necessary  to  make  subsequent
adjustment to the amount of fees, AM Online shall negotiate in good faith with Chuangyi Technology to determine the new fee. The
technology development agreements are effective for ten years and such terms is automatically renewed upon its expiry unless either
party informs the other party of its intention of no extension at least twenty days prior to the expiration of the agreements.

Exclusive  Technology  Consultation  and  Service  Agreement:  AM  online  exclusively  engages  Chuangyi  Technology  to  provide
consultation services in relation to management, training, marketing and promotion. AM Online agrees to pay to Chuangyi Technology
the  amount  of  annual  service  fees  as  determined  by  Chuangyi  Technology.  In  the  event  Chuangyi  Technology  finds  it  necessary  to
make subsequent adjustment to the amount of fees, AM Online shall negotiate in good faith with Chuangyi Technology to determine
the  new  fees.  The  exclusive  technology  consultation  and  service  agreement  remains  effective  for  ten  years  and  such  term  may  be
reviewed by Chuangyi Technology’s written confirmation prior to the expiration of the agreement term.

F-12

 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

The VIE arrangements - continued

·

Call option agreement : Under the call option agreements between Chuangyi Technology and the shareholders of Linghang Shengshi,
Beijing Yuehang and Jiaming Advertising, the shareholders of those VIEs irrevocably granted Chuangyi Technology or its designated
third party an exclusive option to purchase from the VIEs' shareholders, to the extent permitted under PRC law, all the equity interests
in  the  VIEs,  as  the  case  may  be,  for  the  minimum  amount  of  consideration  permitted  by  the  applicable  law  without  any  other
conditions. Under the call option agreements between Chuangyi Technology and the shareholders of AM Online, the shareholders of
AM  Online  irrevocably  granted  Chuangyi  Technology  or  its  designated  third  party  an  exclusive  option  to  purchase  from  the
shareholders of AM Online, to the extent permitted under PRC law, all the equity interests in AM Online, as the case may be. To the
extent the applicable PRC law does not require the valuation of the subject equity interests and does not otherwise restrict the purchase
price for such equity interests, such purchase price shall equal the amount of actual payment made by the respective shareholders of
AM Online with respect to the equity interests whether in the form or share capital injection or secondary purchase price. If and where
the applicable PRC law requires the valuation of the subject equity interests or otherwise has restrictions on the purchase price for such
equity interests, such purchase price shall equal the minimum amount of consideration permitted by the applicable law. In addition,
under  these  agreements  (except  for  the  call  option  agreements  between  Chuangyi  Technology  and  the  shareholders  of  AM  Online),
Chuangyi Technology has undertaken to act as guarantor of VIEs in all operations-related contracts, agreements and transactions and
commit to provide loans to support the business development needs of VIEs or if the VIEs suffer operating difficulties, provided that
the relevant VIE's shareholders satisfy the terms and conditions in the call option agreements. Under PRC laws, to provide an effective
guarantee, a guarantor needs to execute a specific written agreement with the beneficiary of the guarantee. As Chuangyi Technology
has  not  entered  into  any  written  guarantee  agreements  with  any  third  party  beneficiaries  to  guarantee  the  VIEs'  performance
obligations to these third parties, none of these third parties can demand performance from Chuangyi Technology as a guarantor of the
VIEs' performance obligations. The absence of a written guarantee agreement, however, does not affect our conclusion that the Group
is the primary beneficiary of the VIEs and in turn should consolidate the financials of the VIEs. The term of each call option agreement
is ten years and such terms can be renewed upon expiration at Chuangyi Technology's sole discretion.

F-13

 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

The VIE arrangements - continued

·

·

Equity pledge agreement: Under the equity pledge agreements between Chuangyi Technology and the shareholders of our VIEs other
than AM Online, the shareholders of those VIEs pledged all of their equity interests, including the right to receive declared dividends,
in  those  VIEs  to  Chuangyi  Technology  to  guarantee  those  VIEs'  performance  of  their  obligations  under  the  technology  support  and
service agreement and the technology development agreement. Under the equity pledge agreements between Chuangyi Technology and
the  shareholders  of  AM  Online,  the  shareholders  of  AM  Online  pledged  all  of  their  equity  interests,  including  the  right  to  receive
declared dividends, in AM Online to Chuangyi Technology to guarantee the performance by AM Online of its obligations under its call
option agreement and its exclusive technology consultation and service agreement. If the VIEs fail to perform their obligations set forth
in the applicable agreements, Chuangyi Technology shall be entitled to exercise all the remedies and powers set forth in the provisions
of  the  applicable  equity  pledge  agreements.  Those  agreements  remain  effective  for  as  long  as  the  technology  support  and  service
agreements and technology development agreement are effective, or, in the case of AM Online, until two years after the term of the
obligations under the call option agreement and exclusive technology consultation and service agreement.

Authorization letter: Each shareholder of the VIEs has executed an authorization letter to authorize Chuangyi Technology to exercise
certain of its rights, including voting rights, the rights to enter into legal documents and the rights to transfer any or all of its equity
interest in the VIEs. The authorization letters by the shareholders of our VIEs other than AM Online will remain effective during the
operating  periods  of  the  respective  VIEs.  Such  authorization  is  effective  for  ten  years  and  such  term  is  renewed  upon  its  expiry  at
Chuangyi Technology's sole discretion. The authorization letters by the shareholders of AM Online will remain effective for as long as
the  respective  parties  remain  shareholders  of  AM  Online  unless  terminated  earlier  by  Chuangyi  Technology  or  the  call  option
agreement with respect to AM Online is terminated prior to its expiration.

Through the above contractual arrangements, Chuangyi Technology has obtained 100% of shareholders' voting interest in the VIEs, has the right to
receive all dividends declared and paid by the VIEs and may receive substantially all of the net income of the VIEs through the technical support and
service  fees  as  determined  by  Chuangyi  Technology  at  its  sole  discretion.  Accordingly,  the  Group  has  consolidated  the  VIEs  because  the  Group
believes,  through  the  contractual  arrangements,  (1)  Chuangyi  Technology  could  direct  the  activities  of  the  VIEs  that  most  significantly  affect  its
economic performance and (2) Chuangyi Technology could receive substantially all of the benefits that could be potentially significant to the VIEs.
Other than the contractual arrangements described above, because the management and certain employees of Chuangyi Technology also serve in the
VIEs as management or employees, certain operating costs paid by Chuangyi Technology, such as payroll costs and office rental, were re-charged to
the VIEs.

F-14

 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

The VIE arrangements - continued

Chuangyi Technology also entered into loan agreements with each shareholder of AM Online, pursuant to which Chuangyi Technology permits to
make loans in an aggregate amount of RMB 40,000 to the shareholders of AM Online solely for the incorporation and capitalization of AM Online.
The loan is interest free and the term of the loan is ten years and shall be automatically renewed on an annual basis unless Chuangyi Technology
objects. Chuangyi Technology can require the shareholders to repay all or a portion of the loan before the maturity date with a 15 days prior written
notice. Under such circumstances, Chuangyi Technology is entitled to, or designate a third party to, buy all or a portion of the shareholders' equity
interests in AM Online on a pro rata basis based on the amount of the repaid principal of the loan.

F-15

 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

Risks in relation to the VIE structure

The Group believes that the VIE arrangements are in compliance with PRC law and are legally enforceable. The shareholders of the VIEs are also
shareholders of the Group and therefore have no current interest in seeking to act contrary to the contractual arrangements. However, uncertainties in
the PRC legal system could limit the Group's ability to enforce these contractual arrangements and if the shareholders of the VIEs were to reduce
their interest in the Group, their interests may diverge from that of the Group and that may potentially increase the risk that they would seek to act
contrary to the contractual terms, for example by influencing the VIEs not to pay the service fees when required to do so.

The  Group's  ability  to  control  the  VIEs  also  depends  on  the  authorization  letters  that  Chuangyi  Technology  has  to  vote  on  all  matters  requiring
shareholder approval in the VIEs. As noted above, the Group believes the rights granted by the authorization letters is legally enforceable but may
not be as effective as direct equity ownership.

In addition, if the legal structure and contractual arrangements were found to be in violation of any existing PRC laws and regulations, the PRC
government could:

·

·

·

·

revoke the business and operating licenses of the Group's PRC subsidiaries and affiliates;

discontinue or restricting the Group's PRC subsidiaries' and affiliates' operations;

impose conditions or requirements with which the Group or its PRC subsidiaries and affiliates may not be able to comply; or

require the Group or its PRC subsidiaries and affiliates to restructure the relevant ownership structure or operations;

The  imposition  of  any  of  these  penalties  may  result  in  a  material  and  adverse  effect  on  the  Group's  ability  to  conduct  the  Group's  business.  In
addition, if the imposition of any of these penalties causes the Group to lose the rights to direct the activities of the VIEs and its subsidiaries or the
right to receive their economic benefits, the Group would no longer be able to consolidate the VIEs. The Group does not believe that any penalties
imposed or actions taken by the PRC Government would result in the liquidation of the Group, Chuangyi Technology, or the VIEs.

F-16

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES – continued

Risks in relation to the VIE structure - continued

Certain  shareholders  of  VIEs  are  also  beneficial  owners  or  directors  of  the  Company.  In  addition,  certain  beneficial  owners  and  directors  of  the
Company  are  also  directors  or  officers  of  VIEs.  Their  interests  as  beneficial  owners  of  VIEs  may  differ  from  the  interests  of  the  Company  as  a
whole. The Company cannot be certain that if conflicts of interest arise, these parties will act in the best interests of the Company or that conflicts of
interests  will  be  resolved  in  the  Company's  favor.  Currently,  the  Company  does  not  have  existing  arrangements  to  address  potential  conflicts  of
interest these parties may encounter in their capacity as beneficial owners of VIEs, on the one hand, and as beneficial owners of the Company, on the
other hand. The Company believes the shareholders of VIEs will not act contrary to any of the contractual arrangements and the exclusive purchase
right contract provides the Company with a mechanism to remove them as shareholders of VIEs should they act to the detriment of the Company. If
any conflict of interest or dispute between the Company and the shareholders of VIEs arises and the Company is unable to resolve it, the Company
would have to rely on legal proceedings in the PRC. Such legal proceedings could result in disruption of its business; moreover, there is substantial
uncertainty as to the ultimate outcome of any such legal proceedings.

The following financial statement information for AirMedia's VIEs were included in the accompanying consolidated financial statements, presented
net of intercompany eliminations, as of and for the years ended December 31:

Total current assets
Total non-current assets

Total assets

Total current liabilities
Total non-current liabilities

Total liabilities

As of December 31,

2017

2018

  $

73,362    $
122,489     

53,573 
60,375 

195,851     

113,948 

63,302     
25,528     

99,895 
2,763 

  $

88,830    $

102,658 

Net revenues
Net loss

  $

16,311    $
(81,659)    

23,759    $
(173,516)    

24,546 
(86,344)

F-17

For the years ended December 31,
2017

2016

2018

 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
   
 
 
   
 
   
      
  
   
 
   
      
  
   
   
 
   
      
  
 
 
 
 
 
 
   
   
 
 
 
 
   
 
   
 
 
   
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

1.

ORGANIZATION AND PRINCIPAL ACTIVITIES - continued

Risks in relation to the VIE structure - continued

The VIEs contributed an aggregate of 98.8%, 100.0% and 100.0% of the consolidated net revenues for the years ended December 31, 2016, 2017
and  2018,  respectively.  As  of  December  31,  2017  and  2018,  the  VIEs  accounted  for  an  aggregate  of  85.6%  and  87.8%,  respectively,  of  the
consolidated total assets, and 85.6% and 88.9%, respectively, of the consolidated total liabilities.

There are no consolidated VIEs' assets that are collateral for the VIEs' obligations and can only be used to settle the VIEs' obligations. There are no
creditors (or beneficial interest holders) of the VIEs that have recourse to the general credit of the Company or any of its consolidated subsidiaries.
There are no terms in any arrangements, considering both explicit arrangements and implicit variable interests, which require the Company or its
subsidiaries to provide financial support to the VIEs. However, if the VIEs ever need financial support, the Company or its subsidiaries may, at its
option  and  subject  to  statutory  limits  and  restrictions,  provide  financial  support  to  its  VIEs  through  loans  to  the  shareholder  of  the  VIEs  or
entrustment loans to the VIEs.

On December 23, 2018, the State Council submitted the draft version of the Foreign Investment Law to the Standing Committee of the National
People’s Congress, which was promulgated by the National People’s Congress on its official site on December 26, 2018 for public consultation until
February 24, 2019. On March 15, 2019, the National People’s Congress approved the Foreign Investment Law, which On December 23, 2018, the
PRC State Council submitted the draft version of the Foreign Investment Law to the Standing Committee of the National People’s Congress, which
was promulgated by the National People’s Congress on its official site on December 26, 2018 for public consultation until February 24, 2019. On
March 15, 2019, the National People’s Congress approved the Foreign Investment Law, which will come into effect on January 1, 2020 and replace
the  trio  of  existing  laws  regulating  foreign  investment  in  China,  namely,  the  Sino-foreign  Equity  Joint  Venture  Enterprise  Law,  the  Sino-foreign
Cooperative Joint Venture Enterprise Law and the Wholly Foreign-invested Enterprise Law, together with their implementation rules and ancillary
regulations.

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

(a)

Basis of presentation

The consolidated financial statements of the Group have been prepared in accordance with accounting principles generally accepted in the
United States of America ("US GAAP").

(b)

Going concern

The Group incurred operating losses and had negative operating cash flows and may continue to generate negative cash flows as the Group
implements its business plan for 2019. There can be no assurance that the continuing efforts to execute the business plan will be successful
and that the Group will be able to continue as a going concern.

The Group incurred losses from operations of $178,804 and $48,752 for the years ended December 31, 2017 and 2018. As of December 31,
2018,  the  Group  had  accumulated  deficit  of  $262,415.  The  Group  had  negative  cash  flows  from  operating  activities  for  the  years  ended
December 31, 2017 and 2018, the net cash used in operating activities was $58,570 and $19,774 for the years ended December 31, 2017
and 2018. These conditions raise substantial doubt about the Group’s ability to continue as a going concern.

The Group intends to meet the cash requirements for the next 12 months from the issuance date of this report through a combination of
bank loan, financing by way of private placements, friends, family and business associates and management financial support. The Group
will focus on the following activities:

1. The Company plans to strengthen the air Wi-Fi business to drive its revenues and bring in cash from operation;

2. The Company is focusing on improving operation efficiency and cost reduction to standardize operations, enhance internal controls, and
create synergy of the Company’s resources; 

3. The Company has also acquired the financial support letter from Mr. Man Guo and Mr. Qing Xu, who have expressed the willingness and
intention to provide the necessary financial support to the Company, so as to enable the Company to meet its liabilities as and when it falls
due and to carry on its business without a significant curtailment of operations for the next 12 months from the issuance date of this report. 

As  a  result,  management  prepared  the  consolidated  financial  statements  assuming  the  Company  will  continue  as  a  going  concern.  As
described  above,  the  Company  has  a  significant  working  capital  deficiency,  has  incurred  significant  losses  and  needs  to  raise  additional
funds to meet its obligations and sustain its operations. These conditions raise substantial doubt about the Company's ability to continue as a
going concern. Management's plans in regard to these matters are also described above. However, there is no assurance that the measures
above can be achieved as planned. The consolidated financial statements do not include any adjustments that might result from the outcome
of this uncertainty.

F-18

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
   
 
  
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(c)

Basis of consolidation

The consolidated financial statements include the financial statements of the Company, its subsidiaries, its VIEs and its VIEs' subsidiaries.
All inter-company transactions and balances have been eliminated upon consolidation.

(d)

Discontinued operations

A disposal of a component of an entity or a group of components of an entity shall be reported in discontinued operations if the disposal
represents a strategic shift that has (or will have) a major effect on an entity’s operations. Classification as a discontinued operation occurs
upon  disposal  or  when  the  operation  meets  the  criteria  to  be  classified  as  held  for  sale,  if  earlier.  Where  an  operation  is  classified  as
discontinued, a single amount is presented on the face of the consolidated statements of operations. The amount of total current assets, total
non-current  assets,  total  current  liabilities  and  total  non-current  liabilities  are  presented  separately  on  the  consolidated  balance  sheets.  In
2018, the group ceased gas station media business and on long-haul bus Wi-Fi business, and scaled down the on-train Wi-Fi business. As
these three businesses individually or in aggregate have no major effect on the Group’s financial positions, operation and financial result,
the cease of these businesses does not qualify as discontinued operations.

(e)

Use of estimates

The preparation of financial statements in conformity with US GAAP requires to make estimates and assumptions that affect the reported
amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported
amounts  of  revenues  and  expenses  during  the  reporting  period  and  accompanying  notes,  including  allowance  for  doubtful  accounts,  the
useful lives of property and equipment and intangible assets, impairment of long-term investments, impairment of long-lived assets, share-
based compensation and valuation allowance for deferred tax assets. Actual results could differ from those estimates.

(f)

Significant risks and uncertainties

The Group participates in a dynamic industry and believes that changes in any of the following areas could have a material adverse effect
on  the  Group's  future  financial  position,  results  of  operations,  or  cash  flows:  net  losses  in  the  past  and  futures;  failure  in  launching  new
business; a significant or prolonged economic downturn; contraction in the air travel advertising industry in China; competition from other
competitors;  regulatory  or  other  PRC  related  factors;  fluctuations  in  the  demand  for  air  travel;  past  and  future  acquisitions;  failure  to
maintain an effective system of internal control over financial reporting and effective disclosure controls and procedures; risks associated
with the Group's ability to attract and retain employees necessary to support its growth; risks associated with the Group's growth strategies;
and general risks associated with the industry.

F-19

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(g)

Fair value

Fair value is the price that would be received from selling an asset or paid to transfer a liability in an orderly transaction between market
participants  at  the  measurement  date  under  current  market  conditions.  When  determining  the  fair  value  measurements  for  assets  and
liabilities  required  or  permitted  to  be  recorded  at  fair  value,  the  Group  considers  the  principal  or  most  advantageous  market  in  which  it
would transact and it considers assumptions that market participants would use when pricing the asset or liability.

Authoritative literature provides a fair value hierarchy which prioritizes the inputs to valuation techniques used to measure fair value into
three broad levels. The level in the hierarchy within which the fair value measurement in its entirety falls is based upon the lowest level of
input that is significant to the fair value measurement as follows:

Level 1

Level 1 applies to assets or liabilities for which there are quoted prices in active markets for identical assets or liabilities.

Level 2

Level 2 applies to assets or liabilities for which there are inputs other than quoted prices included within Level 1 that are observable for the
asset or liability such as quoted prices for similar assets or liabilities in active markets; quoted prices for identical assets or liabilities in
markets with insufficient volume or infrequent transactions (less active markets); or model-derived valuations in which significant inputs
are observable or can be derived principally from, or corroborated by, observable market data.

Level 3

Level  3  applies  to  assets  or  liabilities  for  which  there  are  unobservable  inputs  to  the  valuation  methodology  that  are  significant  to  the
measurement of the fair value of the assets or liabilities.

F-20

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(h)

Fair value of financial instruments

The Group's financial instruments include cash, accounts receivable, amount due from related parties, accounts payable and amount due to
shareholders. The Group did not have any other financial assets and liabilities or nonfinancial assets and liabilities that are measured at fair
value on recurring basis as of December 31, 2017 and 2018.

The Group's financial assets and liabilities measured at fair value on a non-recurring basis include equity investment and long-lived asset
based on level 2 or 3 inputs.

(i)

Cash and cash equivalents

Cash and cash equivalents consist of cash on hand and highly liquid deposits which are unrestricted as to withdrawal or use, and which have
original maturities of three months or less when purchased.

(j)

Restricted cash

Restricted cash relates to amount required by the bank as frozen accounts by Court mainly due to the litigation as disclosed in Note 23.

F-21

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(k)

Property and equipment , net

Property and equipment are carried at cost less accumulated depreciation. Depreciation is calculated on a straight-line basis over the
following estimated useful lives:

Digital display network equipment
Gas station display network equipment
Wi-Fi
Furniture and fixture
Computer and office equipment
Vehicle
Software
Buildings
Leasehold improvement

5 years
5 years
5 years
5years
3-5 years
5 years
5 years
40 years
Shorter of the term of the lease
or the estimated useful lives of the assets

Costs of repairs and maintenance are expensed as incurred and asset improvements that extend the useful life are capitalized. The gain or
loss on disposal of property and equipment is the difference between the net sales proceeds and the carrying amount of the relevant assets
and is recognized in the consolidated income statement. When property and equipment are retired or otherwise disposed of the cost and
accumulated  depreciation  are  removed  from  the  accounts  and  any  resulting  gain  or  loss  is  included  in  the  results  of  operations  for  the
respective period.

(l)

Impairment of long-lived assets

Long-lived assets held and used by the Group are reviewed for impairment whenever events or changes in circumstances indicate that the
carrying value of such assets may not be fully recoverable. It is possible that these assets could become impaired as a result of technology,
economy  or  other  industry  changes.  If  circumstances  require  a  long-lived  asset  or  asset  group  to  be  tested  for  possible  impairment,  the
Group first compares undiscounted cash flows expected to be generated by that asset or asset group to its carrying value. If the carrying
value of the long-lived asset or asset group is not recoverable on an undiscounted cash flow basis, an impairment is recognized to the extent
that the carrying value exceeds its fair value. Fair value is determined through various valuation techniques, including discounted cash flow
models, relief from royalty income approach, quoted market values and third-party independent appraisals, as considered necessary.

The Group makes various assumptions and estimates regarding estimated future cash flows and other factors in determining the fair values
of the respective assets. The assumptions and estimates used to determine future values and remaining useful lives of long-lived assets are
complex  and  subjective.  They  can  be  affected  by  various  factors,  including  external  factors  such  as  industry  and  economic  trends,  and
internal factors such as the Group’s business strategy and its forecasts for specific market expansion.

F-22

 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES – continued

(m)

Long-term investments

Equity method investments

Investee  companies  over  which  the  Group  has  the  ability  to  exercise  significant  influence,  but  does  not  have  a  controlling  interest  are
accounted for using the equity method. Significant influence is generally considered to exist when the Group has an ownership interest in
the voting stock of the investee between 20% and 50%, and other factors, such as representation on the investee's Board of Directors, voting
rights and the impact of commercial arrangements, are considered in determining whether the equity method of accounting is appropriate.

Cost method investments

For  investments  in  an  investee  over  which  the  Group  does  not  have  significant  influence,  the  Group  carries  the  investment  at  cost  and
recognizes income as any dividends declared from distribution of investee's earnings. The Group reviews the cost method investments for
impairment whenever events or changes in circumstances indicate that the carrying value may no longer be recoverable. An impairment
loss is recognized in earnings equal to the difference between the investment's carrying amount and its fair value at the balance sheet date of
the  reporting  period  for  which  the  assessment  is  made.  All  equity  investments,  except  those  accounted  for  under  the  equity  method  of
accounting or those resulting in the consolidation of the investee, be accounted for at fair value with all fair value changes recognized in
income. For equity investments that do not have readily determinable fair values the Group measures the equity investment at cost minus
impairment,  if  any,  plus  or  minus  changes  resulting  from  observable  price  changes  in  orderly  transactions  for  the  identical  or  a  similar
investment of the Group.

Impairment for long-term investments

The  Group  assesses  its  long-term  investments  for  other-than-temporary  impairment  by  considering  factors  including,  but  not  limited  to,
current economic and market conditions, operating performance of the companies, including current earnings trends and undiscounted cash
flows,  and  other  company-specific  information.  The  fair  value  determination,  particularly  for  investments  in  privately-held  companies,
requires significant judgment to determine appropriate estimates and assumptions. Changes in these estimates and assumptions could affect
the calculation of the fair value of the investments and determination of whether any identified impairment is other-than-temporary. Other-
than-temporary  impairment  loss  is  recognized  in  the  consolidated  statements  of  comprehensive  income  equal  to  the  excess  of  the
investment’s carrying value over its fair value at the balance sheet date of the reporting period for which the assessment is made. The fair
value would then become the new cost basis of such investment.

F-23

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(n)

Revenue recognition

On January 1, 2018, the Group adopted ASC Topic 606, “Revenue from Contracts with Customers”, applying the modified retrospective
method. The adoption did not result in a material adjustment to the accumulated deficit as of January 1, 2018.

In accordance with ASC Topic 606, revenues are recognized when control of the promised goods or services is transferred to the Group’s
customers,  in  an  amount  that  reflects  the  consideration  the  Group  expects  to  be  entitled  to  in  exchange  for  those  goods  or  services.  In
determining  when  and  how  much  revenue  is  recognized  from  contracts  with  customers,  the  Group  performs  the  following  five-step
analysis: (1) identify the contract(s) with a customer; (2) identify the performance obligations in the contract; (3) determine the transaction
price; (4) allocate the transaction price to the performance obligations in the contract; (5) recognize revenue when (or as) the entity satisfies
a performance obligation.

The Group’s contract with customers do not include multiple performance obligations, significant financing component and any variable
consideration.

The Group is a principal as it controls the specified good or service before that good or service is transferred to a customer. The Group is
primarily  responsible  for  fulfilling  the  promise  to  provide  the  specified  good  or  service,  has  inventory  risk  before  the  specified  good  or
service has been transferred to a customer and has discretion in establishing the price for the specified good or service.

Generally, the Group recognizes revenue under ASC Topic 606 for each type of its performance obligation either over time (generally, the
transfer of a service) or at a point in time (generally, the transfer of content) as follows:

The Group's revenues are derived from selling advertising time slots on the Group's advertising networks. For the years ended December
31, 2016, 2017 and 2018, the advertising revenues were generated from air travel media network including TV-attached digital frames in
airports, digital TV screens in airports, digital TV screens on airlines, gas station media network and other media network such as on-train
and on long-haul bus Wi-Fi.

Revenue by service categories

Revenues from operations:

Air Travel Media Network
Gas Station Media Network
Other Media

For the years ended December 31,
2017

2016

2018

  $

  $

12,178    $
4,009     
410     
16,597    $

18,702    $
4,093     
1,533     
24,328    $

22,212 
413 
2,151 
24,776 

Air Travel Media Network: Through air travel media network, revenues were generated from digital frames in airports in the form of TV-
attached digital frames, digital TV screens in airports, digital TV screens on airplanes. There are also other revenues in air travel mainly
include revenues from the display of media contents in air travel. For the advertising business, the Group typically signs standard contracts
with its advertising clients, who require the Group to run the advertiser's advertisements on the Group's network in airports, airlines for a
period of time which is the only performance obligation for a fixed price agreed in the contracts without variable considerations. The Group
recognizes advertising revenues ratably over the service period for which the advertisements are displayed, so long as collection remains
probable. For the program display business, the Group typically signs standard contracts with the customer who has the copyright of movies
or TV programs and requires the Group to play the program on the Group's digital TV screens on airlines for a period of time which is the
only  performance  obligation  for  a  fixed  price  agreed  in  the  contract.  The  Group  recognizes  program  display  revenues  ratably  over  the
performance period for which the program is played, so long as collection remains probable.

Gas Station Media Network: Through gas station media network, the Group sells advertising time slots through digital TV screens in gas
stations which is the only performance obligation included in the contracts. The Group signs fixed fee contracts with the end customers or
agencies for a specified period. The revenue is recognized on a straight-line basis over the specified period. This business is ceased in 2018
and no revenue will be generated from gas station in following years.

Other  Media:  Through  other  media  network  such  as  on-train  and  on  long-haul  bus  Wi-Fi,  the  Group  provides  Wechat  public  account
promotion through Wi-Fi network and advertising and promotion articles publishing on both self-owned and third parties’ public accounts.
Wechat public account is an application account applied by individual, business or enterprise on the Wechat Public Platform through which
communication and interaction with specific groups of words, pictures, voice and video can be achieved. For the public account promotion
business, the passengers in the trains could connect to Wi-Fi for free via the Group's Wi-Fi equipment after registered as a member to that
public account as a follower in WeChat. The Group charges a fix rate per new member and collects service fee from the client who owns the
public  accounts.  The  Group  typically  signs  standard  contracts  with  its  clients,  who  require  the  Group  to  promote  their  public  accounts
which is the only performance obligation defined in the contracts, and recognizes public account promotion revenue by the quantities of
members over the performance period multiplied by unit price defined in the contract. For the advertising and promotion articles publishing
business,  the  group  has  developed  a  public  accounts  pool  which  have  already  accumulated  hundreds  and  thousands  of  registered  users

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
   
      
      
  
 
   
      
      
  
   
   
 
 
 
 
(there are both self-owned and third parties’ public accounts). The Group typically signs standard contracts with its clients, who require the
Group to publish advertising articles on the public accounts to take advantage of the existing users and recognizes advertising revenues by
numbers of articles published on public accounts and the unit price that defined in the contract which differs on the basis of user numbers of
selected public accounts.

Deferred revenue

Prepayments  from  customers  for  advertising  service  are  deferred  when  corresponding  performance  obligation  is  not  satisfied  and
recognized as revenue when the advertising services are rendered. The balance of deferred revenue as of December 31, 2018 is $1,995, the
majority of which is $1,139 for the unsatisfied performance obligation with two customers with contracts amount of $5,672.

Nonmonetary exchanges

The  Group  occasionally  exchanges  advertising  time  slots  and  locations  with  other  entities  for  assets  or  services,  such  as  equipment  and
other assets. The amount of assets and revenue recognized is based on the fair value of the advertising provided or the fair value of the
transferred assets, whichever is more readily determinable. There were no revenue recognized for nonmonetary transactions for the years
ended December 31, 2016, 2017 and 2018. No direct costs are attributable to the revenues.

F-24

 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(o)

Value Added Tax ("VAT")

The  Company's  PRC  subsidiaries  are  subject  to  value-added  taxes  at  a  rate  of  6%  on  revenues  from  advertising  services  and  paid  after
deducting  input  VAT  on  purchases.  The  net  VAT  balance  between  input  VAT  and  output  VAT  is  reflected  in  the  account  as  input  VAT
receivable or other taxes payable.

In July 2012, the Ministry of Finance and the State Administration of Taxation jointly issued a circular regarding the pilot collection of VAT
in lieu of business tax in certain areas and industries in the PRC, including Beijing, Jiangsu, Anhui, Fujian, Guangdong, Tianjin, Zhejiang,
and Hubei between September and December 2012. Also a circular issued in May 2013 provided that such VAT pilot program is rolled out
nationwide since August 2013. Since then, certain subsidiaries and VIEs became subject to VAT at the rates of 6% or 3%, on certain service
revenues which were previously subject to business tax. The Company’s gross revenue is presented net of VAT.

F-25

 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(p)

Concession fees

The Group enters concession right agreements with vendors such as airlines, railway bureaus and petroleum companies, under which the
Group obtains the right to use the spaces or equipment of the vendors to display the advertisements.

Fees under concession right agreements are usually due every three, six or twelve months. Payments made are recorded as current assets
and current liabilities according to the respective payment terms. Most of the concession fees with airlines and railway bureaus are fixed
with  escalation,  which  means  a  fixed  increase  over  each  year  of  the  agreements.  The  total  concession  fee  under  the  concession  right
agreements with airlines is charged to the consolidated statements of operations on a straight-line basis over the agreement periods, which is
generally between three to five years.

The fee structure of the concession right agreement with the petroleum companies is based on the actual number of developed gas stations
and associated standard annual concession fee for each developed gas station. Each gas station has its specific lease term starting from the
time when it is actually put into operation. The calculation of rental payments is based on how many months the gas stations are actually put
into operation during the year and the standard annual concession fee determined based on the location of the gas station. The amount of
annual  concession  fee  to-be-paid  is  determined  by  an  actual  incurred  concession  fee  or  a  fixed  minimum  payment,  if  any,  based  on
negotiation with the petroleum company.

In  2018,  the  Group  ceased  our  long-haul  buses  Wi-Fi  service  operations  and  gas  station  media  services,  and  scaled  down  operations  in
providing Wi-Fi services on trains. The concession fees due to the petroleum companies will be settled by providing equipment and future
free service. Other prepaid concession fees made to railway bureaus are returned or to be returned in the future.

(q)

Agency fees and Advertisement Publishing Fees

The  Group  pays  fees  to  advertising  agencies  for  identifying  and  introducing  advertisers  to  the  Group  and  assisting  in  advertisement
publishing based on a certain percentage of revenues made through the advertisement agencies upon receipt of payment from advertisers.
The agency fees and advertisement publishing fees are charged to cost of revenues in the consolidated statements of operations ratably over
the  period  in  which  the  advertisement  is  displayed.  Prepaid  and  accrued  agency  fees  and  advertisement  publishing  fees  are  recorded  as
current assets and current liabilities according to relative timing of payments made and advertising service provided.

F-26

 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(r)

Operating leases

Leases where substantially all the rewards and risks of ownership of assets remain with the leasing company are accounted for as operating
lease. Payments made under operating leases are charged to the consolidated statements of operations on a straight-line basis over the lease
periods.

(s)

Advertising costs

The Group expenses advertising costs as incurred. Total advertising expenses were $720, $1,209 and $623 for the years ended December
31, 2016, 2017 and 2018, respectively, and have been included as part of selling and marketing expenses.

(t)

Foreign currency translation

The functional and reporting currency of the Company and the Company's subsidiaries domiciled in BVI and Hong Kong are the United
States dollar ("U.S. dollar"). The financial records of the Company's other subsidiaries, VIEs and VIEs' subsidiaries located in the PRC are
maintained in their local currency, the Renminbi ("RMB"), which are the functional currency of these entities.

Monetary assets and liabilities denominated in currencies other than the functional currency are translated into the functional currency at the
rates  of  exchange  ruling  at  the  balance  sheet  date.  Transactions  in  currencies  other  than  the  functional  currency  during  the  year  are
converted  into  functional  currency  at  the  applicable  rates  of  exchange  prevailing  when  the  transactions  occurred.  Transaction  gains  and
losses are recognized in the statements of operations.

The  Group's  entities  with  functional  currency  of  RMB  translate  their  operating  results  and  financial  position  into  the  U.S.  dollar,  the
Company's reporting currency. Assets and liabilities are translated using the exchange rates in effect on the balance sheet date. Revenues,
expenses, gains and losses are translated using the average rate for the year. Retained earnings and equity are translated using the historical
rate.  Translation  adjustments  are  reported  as  cumulative  translation  adjustments  and  are  shown  as  a  separate  component  of  other
comprehensive income.

F-27

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(u)

Income taxes

Deferred income taxes are recognized for temporary differences between the tax basis of assets and liabilities and their reported amounts in
the financial statements, net operating loss carry forwards and credits, by applying enacted statutory tax rates applicable to future years.
Deferred tax assets are reduced by a valuation allowance when, in the opinion of management, it is more likely than not that some portion
or  all  of  the  deferred  tax  assets  will  not  be  realized.  Current  income  taxes  are  provided  for  in  accordance  with  the  laws  and  regulations
applicable to the Group as enacted by the relevant tax authorities.

The impact of an uncertain income tax position on the income tax return must be recognized at the largest amount that is more-likely-than
not to be sustained upon audit by the relevant tax authorities. An uncertain income tax position will not be recognized if it has less than a
50% likelihood of being sustained. Additionally, the Group classifies the interest and penalties, if any, as a component of the income tax
expense. According to the PRC Tax Administration and Collection Law, the statute of limitations is three years if the underpayment of taxes
is  due  to  computational  errors  made  by  the  taxpayer  or  the  withholding  agent.  The  statute  of  limitations  is  extended  to  five  years  under
special  circumstances,  where  the  underpayment  of  taxes  is  more  than  RMB  100.  In  the  case  of  transfer  pricing  issues,  the  statute  of
limitation is ten years. There is no statute of limitation in the case of tax evasion. According to Hong Kong Inland Revenue Department, the
statute  of  limitation  is  six  years  if  any  company  chargeable  with  tax  has  not  been  assessed  or  has  been  assessed  at  less  than  the  proper
amount, the statute of limitation is extended to 10 years if the underpayment of taxes is due to fraud or willful evasion. In 2018, the Group
incurred  penalties  of  $4,324  related  to  underpayment  or  delayed  payment  for  income  tax  expense  of  previous  years.  The  tax  penalty  of
$2,664 is charged for one-year delay of income tax payment of 2015 rising from the gain on transferring 75% equity of AM Advertising and
the  tax  penalty  of  $1,660  is  charged  for  the  unpaid  income  tax  expense  of  2016  for  the  deduction  of  bad  debt  allowance  from  taxable
income before tax without chasing up for debt and filing a special declaration of loss in asset. As of December 31, 2018, all the penalties
have been paid off. For the transferring 20.32% equity of AM Advertising of which the industrial and commercial registration procedure
was completed in December 2018, the Group has filed this equity transaction in the first quarter tax return filling in early 2019. For the
deduction of bad allowance, the inspection method has been changed from filing a declaration to reporting the loss by taxpayer. Hence, the
Group  did  not  have  any  material  outstanding  interest  or  penalties  associated  with  tax  positions  nor  did  the  Group  have  any  significant
unrecognized uncertain tax positions. The Group does not expect that its assessment regarding unrecognized tax positions will materially
change over the next 12 months. The Group is not currently under examination by an income tax authority, nor has been notified that an
examination is contemplated.

(v)

Share-based payments

Share-based  payment  transactions  with  employees  are  measured  based  on  the  grant  date  fair  value  of  the  equity  instrument  issued,  and
recognized  as  compensation  expenses  over  the  requisite  service  periods  based  on  a  straight-line  method,  with  a  corresponding  impact
reflected in additional paid-in capital.

Share-based payment transactions with non-employees are measured based on the fair value of the options on the measurement date as of
each reporting date, with a corresponding impact reflected in additional paid-in capital.

F-28

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(w)

Comprehensive loss

Comprehensive loss includes net loss and foreign currency translation adjustments and is presented net of tax. The tax effect is nil for the
three years ended December 31, 2016, 2017 and 2018 in the consolidated statements of comprehensive loss.

(x)

Allowance of doubtful accounts

The  Group  conducts  credit  evaluations  of  clients  and  generally  does  not  require  collateral  or  other  security  from  clients.  The  Group
establishes an allowance for doubtful accounts based upon estimates, historical experience and other factors surrounding the credit risk of
specific clients and utilizes both specific identification and a general reserve to calculate allowance for doubtful accounts. The amounts of
receivables  ultimately  not  collected  by  the  Group  have  generally  been  consistent  with  expectations  and  the  allowance  established  for
doubtful  accounts.  If  the  frequency  and  amount  of  customer  defaults  change  due  to  the  clients'  financial  condition  or  general  economic
conditions,  the  allowance  for  uncollectible  accounts  may  require  adjustment.  As  a  result,  the  Group  continuously  monitors  outstanding
receivables and adjusts allowances for accounts where collection may be in doubt.

(y)

Concentration of credit risk

Financial instruments that potentially expose the Group to concentrations of credit risk consist primarily of cash and accounts receivable.
The Group places their cash with financial institutions with high-credit rating and quality in China. There are two customers accounting for
10% or more of total revenue as of December 31, 2018, and there is one customer accounting for 10% of total revenue as of December 31,
2017. There is a customer accounting for 10% or more of total accounts receivables as of December 31, 2018, and there is no customer
accounting for 10% or more of total accounts receivables as of December 31, 2017.

(z)

Net loss per share

Basic net loss per share are computed by dividing net loss attributable to holders of ordinary shares by the weighted average number of
ordinary shares outstanding during the year. Diluted net loss reflects the potential dilution that could occur if securities or other contracts to
issue  ordinary  shares  were  exercised  or  converted  into  ordinary  shares.  Potential  common  shares  in  the  diluted  net  loss  per  share
computation are excluded in periods of losses, as their effect would be anti-dilutive.

(aa)

Government subsidies

The Group primarily receives tax refund and development supporting bonus from tax bureau and local government without any condition or
restriction. The government subsidies are recorded in other income on the consolidated statements of operations in the period in which the
amounts of such subsidies are received without future performance requirement. The recognized government subsidies as other income are
$86, nil and $10 for the years ended December 31, 2016, 2017 and 2018, respectively.

F-29

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(bb)

Recent issued accounting standards

In February 2016, the FASB issued ASU 2016-02, Leases (Topic 842). The guidance supersedes existing guidance on accounting for leases
with the main difference being that operating leases are to be recorded in the statement of financial position as right-of-use assets and lease
liabilities, initially measured at the present value of the lease payments. For operating leases with a term of 12 months or less, a lessee is
permitted to make an accounting policy election not to recognize lease assets and liabilities. For public business entities, the guidance is
effective for fiscal years beginning after December 15, 2018, including interim periods within those fiscal years. Early application of the
guidance is permitted. In transition, entities are required to recognize and measure leases at the beginning of the earliest period presented
using a modified retrospective approach. In July 2018, the FASB issued ASU No. 2018-10 and No. 2018-11, Leases (ASC 842). ASU 2018-
10 provides narrow amendments that clarify how to apply certain aspects of the guidance in ASU 2016-02. ASU 2018-11 provides entities
with an option of an additional transition method, by allowing entities to initially apply the new leases standard at the adoption date and
recognize a cumulative-effect adjustment to the opening balance of retained earnings in the period of adoption. It also provides lessors an
option to not separate lease and non-lease components when certain criteria are met. In December 2018, the FASB issued ASU No. 2018-
20, Leases (Topic 842), Narrow-Scope Improvements for Lessors, which clarifies the accounting by lessors for taxes collected from lessees,
certain lessor costs either paid by lessees directly to third parties or paid by the lessor and reimbursed by the lessee, and variable payments
received  by  lessors  for  contracts  with  lease  and  non-lease  components.  In  March  2019,  the  FASB  issued  ASU  2019-01,  Codification
Improvements, which clarifies certain aspects of the new lease standard. The Group adopted the amendments in these ASUs on January 1,
2019 using the additional modified retrospective transition method provided by ASU No. 2018-11. The adoption did not result in a material
adjustment  to  the  Group’s  accumulated  deficit  as  of  January  1,  2019.  Based  on  the  Group’s  current  office  space  lease  agreements  as  of
December 31, 2018, the remaining balances of the right-of-use asset and related lease payment liability are $2,772 and $2,766, respectively,
under modified retrospective approach review.

In  June  2016,  the  FASB  issued  ASU  No.  2016-13,  “Financial  Instruments  –  Credit  Losses”,  which  will  require  the  measurement  of  all
expected credit losses for financial assets held at the reporting date based on historical experience, current conditions, and reasonable and
supportable  forecasts.  In  November  2018,  the  FASB  issued  ASU  No.  2018-19,  “Codification  Improvements  to  Topic  326,  Financial
Instruments-Credit Losses”, which among other things, clarifies that receivables arising from operating leases are not within the scope of
Subtopic 326-20. Instead, impairment of receivables arising from operating leases should be accounted for in accordance with Topic 842,
Leases.  For  public  entities,  the  amendments  in  these  ASU  are  effective  for  fiscal  years  beginning  after  December  15,  2019,  including
interim  periods  within  those  fiscal  years.  The  Group  is  currently  evaluating  this  statement  and  its  impact  on  its  results  of  operations  or
financial position. 

In February 2018, the FASB issued ASU 2018-02, Income Statement Reporting Comprehensive Income (Topic 220). The amendments in
this Update allow a reclassification from accumulated other comprehensive income to retained earnings for stranded tax effects resulting
from the Tax Cuts and Jobs Act. Consequently, the amendments eliminate the stranded tax effects resulting from the Tax Cuts and Jobs Act
and will improve the usefulness of information reported to financial statement users. However, because the amendments only relate to the
reclassification of the income tax effects of the Tax Cuts and Jobs Act, the underlying guidance that requires that the effect of a change in
tax  laws  or  rates  be  included  in  income  from  continuing  operations  is  not  affected.  The  amendments  in  this  Update  also  require  certain
disclosures  about  stranded  tax  effects.  Public  business  entities  should  apply  the  amendments  in  ASU  2018-02  for  fiscal  years  beginning
after  December  15,  2018,  and  interim  periods  within  those  fiscal  years.  Early  adoption  of  the  amendments  in  this  Update  is  permitted,
including adoption in any interim period, (1) for public business entities for reporting periods for which financial statements have not yet
been issued and (2) for all other entities for reporting periods for which financial statements have not yet been made available for issuance.
The  Group  has  completed  the  assessment  of  the  adoption  of  this  guidance  on  its  consolidated  financial  statements,  the  adoption  of  this
guidance will not have a material impact on its consolidated financial statements.

F-30

 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

2.

SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES - continued

(bb)

Recent issued accounting standards - continued

In February 2018, the FASB issued guidance to address the income tax accounting treatment of the tax effects within other comprehensive
income due to the enactment of the Tax Cuts and Jobs Act (the “Tax Act”). This guidance allows entities to elect to reclassify the tax effects
of  the  change  in  the  income  tax  rates  from  other  comprehensive  income  to  retained  earnings.  The  guidance  is  effective  for  periods
beginning after December 15, 2018 although early adoption is permitted. In March 2018, the FASB issued ASU No. 2018-05, Income Tax
(Topic  740)  -  Amendments  to  SEC  Paragraphs  Pursuant  to  SEC  Staff  Accounting  Bulletin  No.  118.  This  update  adds  SEC  paragraphs
pursuant to the SEC Staff Accounting Bulletin No. 118, which expresses the view of the staff regarding application of Topic 740, Income
Taxes,  in  the  reporting  period  that  includes  December  22,  2017  -  the  date  on  which  the  Tax  Act  was  signed  into  law.  The  Group  has
completed the assessment of the adoption of this guidance on its consolidated financial statements, the adoption of this guidance will not
have a material impact on its consolidated financial statements.

In June, 2018, the FASB issued ASU No. 2018-07 to provide guidance to reduce cost and complexity and to improve financial reporting for
share-based payments issued to nonemployees (for example, service providers, external legal counsel, suppliers, etc.). The amendments in
this ASU are effective for public companies for fiscal years beginning after December 15, 2018, including interim periods within that fiscal
year. The Group has completed the assessment of the adoption of this guidance on its consolidated financial statements, the adoption of this
guidance will not have a material impact on its consolidated financial statements.

In  August  2018,  the  FASB  issued  ASU  No.  2018-13,  “Fair  Value  Measurement  (Topic  820):  Disclosure  Framework—Changes  to  the
Disclosure  Requirements  for  Fair  Value  Measurement”.  The  amendments  in  this  ASU  eliminate,  add  and  modify  certain  disclosure
requirements  for  fair  value  measurements.  The  amendments  in  this  ASU,  among  other  things,  require  public  companies  to  disclose  the
range and weighted average used to develop significant unobservable inputs for Level 3 fair value measurements. The amendments in this
ASU are effective for all entities for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2019, and
entities are permitted to early adopt either the entire standard or only the provisions that eliminate or modify the requirements. The Group
does not expect the adoption of these amendments to have a material impact on our consolidated financial position and results of operations.

In October 2018, the FASB issued ASU No. 2018-17, Consolidation (Topic 810): Targeted Improvements to Related Party Guidance for
Variable  Interest  Entities.  ASU  2018-17  expands  the  accounting  alternative  that  allows  private  companies  the  election  not  to  apply  the
variable  interest  entity  guidance  to  qualifying  common  control  leasing  arrangements.  ASU  2018-17  broadens  the  scope  of  the  private
company alternative to include all common control arrangements that meet specific criteria (not just leasing arrangements). ASU 2018-17
also eliminates the requirement that entities consider indirect interests held through related parties under common control in their entirety
when assessing whether a decision-making fee is a variable interest. Instead, the reporting entity will consider such indirect interests on a
proportionate  basis.  The  amendments  are  effective  for  public  business  entities  for  fiscal  years  ending  after  December  15,  2019.  Early
adoption  is  permitted.  The  Group  is  currently  assessing  the  timing  and  impact  of  adopting  the  updated  provisions  to  its  consolidated
financial statements.

Recently issued ASUs by the FASB, except for the ones mentioned above, and are not expected to have a significant impact on the Group’s
consolidated results of operations or financial position.

F-31

 
 
 
 
 
 
 
 
  
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

3.

SEGMENT INFORMATION AND REVENUE ANALYSIS

The Group is mainly engaged in selling advertising time slots on their network, primarily air travel advertising network, gas station media network,
throughout PRC.

The  Group  chief  operating  decision  maker  has  been  identified  as  the  Chief  Executive  Officer,  who  reviews  consolidated  results  when  making
decisions about allocating resources and assessing performance of the Group; hence, the Group has only one operating segment.

Geographic information

The Group primarily operates in the PRC and substantially all of the Group's long-lived assets are located in the PRC.

F-32

 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

4.

ACCOUNTS RECEIVABLE, NET

Accounts receivable, net, consists of the following:

Accounts receivable, gross
Less: Allowance for doubtful accounts
Accounts receivable, net

Movement of allowance for doubtful accounts is as follows:

As of December 31,

2017

2018

  $

  $

15,571    $
(4,591)    
10,980    $

13,424 
(5,486)
7,938 

January 1, 2016
Addition
Write off
Exchange rate adjustment
December 31, 2016
Addition
Write off
Exchange rate adjustment
December 31, 2017
Addition
Write off
Exchange rate adjustment
December 31, 2018

  Allowance for doubtful accounts 
1,727 
  $
2,248 
- 
(160)
3,815 
1,403 
(883)
256 
4,591 
1,184 
- 
(289)
5,486 

  $

F-33

 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
     
 
   
 
 
 
   
   
   
   
   
   
   
   
   
   
   
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

5.

OTHER CURRENT ASSETS, NET

Other current assets, net, consist of the following:

Gross

2017
    Allowance    

Net

Gross

2018
    Allowance    

Net

As of December 31,

  $

Input VAT receivable
Prepaid selling and marketing fees
Short-term deposits
Prepaid income tax
Prepaid individual income tax and other
employee advances
Loans to third parties (i)
Receivable from third party (ii)
Receivable from non-controlling interest holders    
Receivable from AM Advertising and its
subsidiaries (iii)
Other prepaid expenses
Others

20,670    $
1,708     
129     
273     

435     
41,733     
4,317     
3,170     

26,160     
7,346     
1,166     

-    $
-     
-     
-     

-     
(40,748)    
(257)    
-     

(3,734)    
(2,543)    
-     

20,670    $
1,708     
129     
273     

435     
985     
4,060     
3,170     

22,426     
4,803     
1,166     

17,540    $
308     
711     
264     

224     
38,242     
4,463     
1,178     

22,726     
6,753     
726     

-    $
-     
-     
-     

-     
(38,061)    
(1,242)    
-     

(8,787)    
(3,988)    
-     

17,540 
308 
711 
264 

224 
181 
3,221 
1,178 

13,939 
2,765 
726 

Total

(i)

(ii)

(iii)

  $

107,107    $

(47,282)   $

59,825    $

93,135    $

(52,078)   $

41,057 

These  third  parties  provide  outdoor  advertising  services  to  their  customers.  Loans  to  third  parties  are  in  order  to  secure  them  to  provide
advertising services at prime locations to the Group. For the years ended December 31, 2017 and 2018, the Group entered into various loan
agreements with third parties with aggregated amount of $41,733 and $38,242, respectively with the terms of one year. The interest rates
were from 4.35% to 5% without any assets pledged for the years ended December 31, 2017 and 2018, respectively. As of December 31,
2017, the management conducted a review on the outstanding loans, and the review discovered that market conditions under which the third
parties competed deteriorated unexpectedly in 2017, which imposed adverse constraints on their ability to repay the loans. As of December
31, 2017 and 2018, the bad debt allowance for loan to third parties amounted to $40,748 and $38,061, respectively.

Receivable  from  third  party  mainly  represented  the  concession  fee  deposits  of  Guangzhou  Meizheng  for  the  down-scaled  operations  in
providing Wi-Fi services on trains that is expected to be refunded within one year. As of December 31, 2017 and 2018, the management
conducted  a  review  on  the  outstanding  balance  and  recorded  bad  debt  provision  on  other  current  assets  for  which  the  collectability  is
assessed to be remote. As of December 31, 2017 and 2018, the bad debt allowance was $257 and $1,242, respectively.

Receivable  from  AM  Advertising  and  its  subsidiaries  balance  amounted  to  $26,160  and  $22,726  as  of  December  31,  2017  and  2018,
respectively.  As  of  December  31,  2017  and  2018,  $3,734  and  $8,787  of  bad  debt  allowance  were  made  for  the  receivable  balance,
respectively. The net balance $13,939 as of December 31, 2018 represents the loan due form AM advertising to support its operations of
RMB88,000 in principal balance and RMB7,840 in interests.

On March 28, 2018, August 23, 2018 and November 2018, the Group entered into a MoU of transaction of 75% equity transfer of AM
Advertising in 2015 and its supplemental agreements with Longde Wenchuang and Beijing Cultural Center Construction and Development
Fund (Limited Partnership), Beijing Linghang Shengshi Advertising Co., Ltd. (“Linghang Shengshi”) and Mr. Guo have agreed to pay or
make available to AM Advertising on or prior to May 30, 2018 and further extended to September 30, 2018 and December 31, 2018 an
aggregate  of  RMB304,554  which  was  to  be  discounted  by  the  following  amounts  (i)  the  RMB152,000  profits  attributable  to  Linghang
Shengshi  for  the  first  nine  months  of  2015;  (ii)  the  loan  of  RMB88,000  in  principal  balance  and  RMB7,840  in  interests;  and  (iii)  the
payment of RMB56,714 in cash. When the MoU is settled in future, the net balance of receivable from AM Advertising and its subsidiaries
will be cleared off.

F-34

 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
   
 
 
   
     
     
     
     
     
 
   
   
   
   
   
   
   
   
   
 
   
      
      
      
      
      
  
  
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

6.

PREPAID CONCESSION FEES

The  Group  enters  concession  right  agreements  with  vendors  such  as  airlines,  railway  bureaus  and  petroleum  companies,  under  which  the  Group
obtains the right to use the spaces or equipment of the vendors to display the advertisements. The balance of prepaid concession fees for the years
ended December 31, 2017 and 2018 are $7,064 and $1,813, respectively. The decline of prepayment is due to amortization and the refund of the
prepaid concession fee during the year ended December 31, 2018. In addition, the scale down of on-train Wi-Fi business leads to recollections and
reduced prepayment made during the year and the balances expected to be collected in 2019 are reclassified to other current assets.

7.

ACQUIRED INTANGIBLE ASSETS, NET

Acquired intangible assets, net, consist of the following:

2017

2018

As of December 31,

  Gross
  carrying     Accumulated    Accumulated    carrying     carrying     Accumulated    Accumulated    carrying  
impairment     amount  
  amount     amortization   

impairment     amount     amount     amortization   

    Gross

Net

Net

Audio-vision programming and broadcasting qualification  $
Customer relationships
Contract backlog
Concession agreements
Non-compete agreements

213    $
735     
1,536     
10,404     
182     

(37)   $
(735)    
(1,536)    
(8,529)    
(172)    

(176)   $
-     
-     
(1,875)    
(10)    

-    $
-     
-     
-     
-     

218    $
751     
1,570     
10,632     
185     

(38)   $
(751)    
(1,570)    
(8,716)    
(175)    

(180)   $
-     
-     
(1,916)    
(10)    

  $

13,070    $

(11,009)   $

(2,061)    

-    $

13,356    $

(11,250)   $

(2,106)    

- 
- 
- 
- 
- 

- 

The amortization expense for the years ended December 31, 2016, 2017 and 2018 were $510, $501 and nil, respectively. Due to the continuing losses
and significant reduced revenue, the Group recognized an impairment loss of $1,228 for the year ended December 31, 2017, all the intangible assets
are fully impaired as of December 31, 2017.

F-35

 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
 
   
 
   
   
 
   
 
   
 
 
 
 
   
     
     
     
     
     
     
     
 
   
   
   
   
 
   
      
      
      
      
      
      
      
  
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

8.

PROPERTY AND EQUIPMENT, NET

Property and equipment, net, consist of the following:

Digital display network equipment
Wi-Fi and network equipment
Gas station display network equipment
Software
Office property
Computer and office equipment
Vehicle
Leasehold improvement
Furniture and fixture
Total original costs
Less: impairment
Less: accumulated depreciation
Construction in progress
Less: impairment on construction in process

 Total property and equipment, net

  $

As of December 31,

2017

2018

6,548    $
36,431     
43,079     
9,764     
11,506     
3,264     
817     
2,262     
994     
114,665     
(51,702)    
(47,521)    
514     
(514)    

6,183 
34,476 
39,523 
9,241 
10,888 
3,058 
773 
2,783 
1,086 
108,011 
(48,885)
(45,660)
569 
(569)

  $

15,442    $

13,466 

Depreciation expense recorded for the years ended December 31, 2016, 2017 and 2018 were $12,461, $11,547 and $1,560 respectively. Impairment
loss recorded for the years ended December 31, 2016, 2017 and 2018 were $826, $49,468 and $564 respectively.

9.

PREPAID EQUIPMENT COST

For  the  year  ended  December  31,  2017,  the  Group  recognized  an  impairment  loss  of  $16,646  for  the  LED  screens  purchased  from  Elec-Tech
International  Co.,  Ltd.  or  its  subsidiaries  as  the  ordered  equipment  was  out  of  dated,  and  the  prepaid  equipment  cost  balance  of  $290  mainly
represented  the  prepayment  made  for  the  leasehold  improvement.  For  the  year  ended  December  31,  2018,  the  prepaid  equipment  cost  balance
represents prepayment for airline Wi-Fi equipment of $2,364.

F-36

 
 
 
 
 
 
 
 
 
 
 
   
 
   
   
   
   
   
   
   
   
   
   
   
   
   
 
   
      
  
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

10.

LONG-TERM INVESTMENTS

(a)

Equity method investments

The  Group  had  the  following  equity  method  investments,  other-than-temporary  impairment  of  $1,993  and  $2,408  were  recognized  as  of
December 31, 2017 and 2018, respectively:

Name of company

Equity method investments

As of December 31,

2017

2018

Percentage of

Percentage of

ownership    

Amount

ownership    

Amount

%

%

Beijing Eastern Media Corporation Ltd. (“BEMC “) (1)

49    $

1,618     

49    $

1,769 

Beijing Hezhong Chuangjin Investment Co., Ltd. ("Hezhong

Chuangjin") (2)

Lanmeihangbiao Tiandi Internet Investment Management

(Beijing) Co., Ltd. ("LMHB") (3)

Beijing Yuyue Film Culture Co., Ltd (“Yuyue Film”) (4)

15     

1,993     

15     

1,886 

40     

25     

223     

362     

40     

25     

179 

343 

Unicom AirNet (Beijing) Network Co., Ltd. ("Unicom AirNet")

(5)

39     

17,422     

39     

15,413 

Less: impairment on equity method investments:
Hezhong Chuangjin (2)
LMHB (3)
Yuyue Film (4)

(1,993)    
-     
-     

(1,886)
(179)
(343)

Equity method investments, net

     $

19,625     

     $

17,182 

(1)

(2)

(3)

(4)

In March 2008, the Group entered into a definitive agreement with China Eastern Media Corporation, Ltd., a subsidiary of China
Eastern Group and China Eastern Airlines Corporation Limited operating the media resources of China Eastern Group, to establish
a joint venture, BEMC. BEMC was incorporated on March 18, 2008 in the PRC with China Eastern Media Corporation and the
Group  holding  51%  and  49%  equity  interest,  respectively.  BEMC  obtained  concession  rights  of  certain  media  resources  from
China  Eastern  Group,  including  the  digital  TV  screens  on  airplanes  of  China  Eastern  Airlines,  and  paid  concession  fees  to  its
shareholders  as  consideration.  The  investment  was  accounted  for  using  the  equity  method  of  accounting  as  the  Group  has  the
ability to exercise significant influence to the operation of BEMC. $198, $57 and $247 gain on investment were picked up for the
years ended December 31, 2016, 2017 and 2018, respectively.

In May 2015, the Group, together with several other third party companies established Hezhong Chuangjin, which mainly focuses
on  internet  financing.  The  investment  was  accounted  for  using  the  equity  method  of  accounting  as  the  Group  has  the  ability  to
exercise significant influence to the operation of Hezhong Chuangjin. $59, $78 and nil loss on investment were picked up for the
years ended December 31, 2016, 2017 and 2018, respectively. The operation has been ceased from December 2017, the investment
has been provided full impairment of $1,993 and $1,886 as of December 31, 2017 and 2018, respectively, with foreign currency
translation adjustment.

In  September  2015,  AM  Online  entered  into  an  agreement  with  BlueFocus  wireless  Internet  (Beijing)  Investment  Management
Co., Ltd. and two individual investors to establish a joint venture, LMHB. LMHB is mainly engaged in investment management of
Wi-Fi  platform  marketing  and  other  mobile  internet  industries.  The  investment  was  accounted  for  using  the  equity  method  of
accounting  as  the  Group  has  the  ability  to  exercise  significant  influence  to  the  operation  of  LMHB.  $175,  $48  and  $33  loss  on
investment  were  picked  up  for  the  years  ended  December  31,  2016,  2017  and  2018,  respectively.  The  investment  has  been
provided full impairment loss of $185 for the year ended December 31, 2018.

In June 2016, AM Film entered into an agreement with two individual investors to establish a joint venture, Yuyue Film. Yuyue
Film is mainly engaged in investment management of film investment and marketing. The investment was accounted for using the
equity method of accounting as the Group has the ability to exercise significant influence to the operation of Yuyue Film. Nil, $95
and nil loss on investment were pick up for the years ended December 31, 2016, 2017 and 2018, respectively. The investment has
been provided full impairment loss of $355 for the year ended December 31, 2018.

(5)

On  February  22,  2017,  AM  Online  established  Unicom  AirNet,  jointly  with  Unicom  Broadband  Online  Co.,  Ltd.  and  Chengdu
Haite Kairong Aeronautical Technology Co., Ltd., a wholly owned subsidiary of a listed company providing aeronautical technical

 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
     
     
     
 
 
   
 
 
 
   
 
   
   
 
 
   
      
      
      
  
 
   
      
      
      
  
   
 
   
      
      
      
  
   
 
   
      
      
      
  
   
 
   
      
      
      
  
   
 
   
      
      
      
  
   
 
   
      
      
      
  
   
      
      
      
  
   
      
      
   
      
      
   
      
      
 
   
      
      
      
  
   
  
 
 
 
 
services. Pursuant to a capital contribution agreement entered into by the relevant parties, AM Online invested RMB117,900 in
Unicom AirNet. After this transaction, AM Online currently holds 39% of equity interests in Unicom AirNet. The investment was
accounted for using the equity method of accounting as the Group has the ability to exercise significant influence to the operation
of  Unicom  AirNet.  $661  and  $1,114  loss  on  investment  was  picked  up  for  the  years  ended  December  31,  2017  and  2018,
respectively.

F-37

 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

10.

LONG-TERM INVESTMENTS - continued

(b)

Cost method investments

The  Group  had  the  following  cost  method  investments,  other-than-temporary  impairment  of  nil  and  $49,273  was  recognized  as  of
December 31, 2017 and 2018, respectively:

Name of company

Zhangshangtong Air Service (Beijing) Co., Ltd.
("Zhangshangtong") (1)

As of December 31,

2017

2018

Percentage of 

Percentage of 

ownership    

Amount

ownership    

Amount

%

%

20    $

415     

20    $

392 

Beijing Zhongjiao Huineng Information Technology Co., Ltd
(“Zhongjiao Huineng”) (2)

13     

577     

13     

546 

AM Advertising (3)

20     

81,817     

20     

77,424 

Less: impairment on cost method investments
Zhangshangtong (1)
Zhongjiao Huineng (2)
AM Advertising (3)

-     
-     
-     

(392)
(546)
(48,335)

Cost method investment, net

     $

82,809     

     $

29,089 

(1) In  June  2010,  the  Group  acquired  20%  equity  interest  in  Zhangshangtong  Air  Service  (Beijing)  Co.,  Ltd.  ("Zhangshangtong"),  a
company  established  in  the  PRC  that  is  mainly  engaged  in  air  tickets  agency  services.  In  2018,  impairment  loss  of  $407  has  been
recorded for this investment considering the carrying value is not recoverable.

(2) In January 2016, the Group acquired 13.3% equity interest in Zhongjiao Huineng, a company established in the PRC that is mainly
engaged  in  providing  WIFI  and  GPS  service  to  logistic  industry.  In  2018,  impairment  loss  of  $567  has  been  recorded  for  this
investment considering the carrying value is not recoverable.

(3) The investment in AM Advertising was accounted for using the cost method of accounting, as the Group does not have the ability to
exercise significant influence to the operation from 2016. In December 2018, the Group transferred the 20.32% equity interests in AM
Advertising  but  did  not  derecognized  this  long-term  investment  considering  the  existence  of  continuing  involvement  and  more  than
trivial benefit owned by the Group. Meanwhile the Group determined the fair value of this investment in AM Advertising according to
the transaction price, which became the new basis of the investment. Hence, the investment impairment loss of nil and $50,159 in AM
Advertising has been recorded for the years ended December 31, 2017 and 2018, respectively.

F-38

 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
     
     
     
 
 
   
 
 
 
   
 
   
   
 
 
   
 
   
      
      
      
  
   
 
   
      
      
      
  
   
 
   
      
      
      
  
   
      
      
      
  
   
      
      
   
      
      
   
      
      
 
   
      
      
      
  
   
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

11.

OTHER NON-CURRENT ASSETS

Other non-current assets consist of the following:

Investment in film and TV series (i)
Leasehold improvement fees (ii)
Less: Impairment on the investment in films and TV series
Total other non-current assets, net

As of December 31,

2017

2018

  $

  $

1,407    $
798     
-     
2,205    $

1,407 
- 
(1,407)
- 

(i)

(ii)

The Group enters into agreements with other investors to invest together on certain films and TV series, which are produced by other third
parties, and shares profit of the invested films and TV series based on its percentage of the total investment for films or TV series. The
investment  has  been  provided  full  impairment  of  $1,407  for  the  year  ended  December  31,  2018  as  the  investment  is  not  expected  to  be
recoverable.

The balance of leasehold improvement fee was $798 as of December 31, 2017, which has been amortized into expense for the year ended
December 31, 2018.

F-39

 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
     
 
   
   
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

12.

LONG-TERM DEPOSITS

Long-term deposits consist of the following:

Concession fee deposits
Office rental deposits

Total long-term deposits

As of December 31,

2017

2018

  $

  $

5,516    $
523     

920 
430 

6,039    $

1,350 

Concession  fee  deposits  normally  have  terms  of  three  to  five  years  and  are  refundable  at  the  end  of  the  concession  terms.  Office  rental  deposits
normally have terms of one to three years and are refundable at the end of the lease term. As the Group ceased the gas station media and on-bus Wi-
Fi  business  and  scaled  down  on-train  Wi-Fi  business,  most  of  concession  fee  deposit  has  been  refunded,  reclassified  into  other  current  assets  or
impaired according to assessment of recoverability.

The  long-term  deposits  are  not  within  the  scope  of  the  ASC  310-10-25  regarding  interests  on  receivables,  because  they  are  intended  to  provide
security for the counterparty to the concession rights or office rental agreements. Therefore, the deposits are recorded at cost.

F-40

 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
     
 
   
 
   
      
  
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

13.

ACCRUED EXPENSES AND OTHER CURRENT LIABILITIES

Accrued expenses and other current liabilities consist of the follows:

Accrued payroll and welfare
Other tax payable
Accrued staff disbursement
Deposit payable
Accrued professional fees
Other current liabilities (i)
Payable to AM Advertising and its subsidiaries (ii)

As of December 31,

2017

2018

  $

2,249    $
1,314     
1,460     
613     
166     
868     
5,566     

  $

12,236    $

1,719 
350 
1,214 
247 
172 
2,500 
3,556 

9,758 

(i)

The  other  current  liabilities  represent  other  payable  to  third  parties  of  $1,265  and  payable  to  capital  withdraw  of  non-controlling
shareholders of $1,235.

(ii)

The amounts due to AM Advertising and its subsidiaries mainly represent the operation borrowings payable.

F-41

 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
     
 
   
   
   
   
   
   
 
   
      
  
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

14.

INCOME TAXES

AirMedia is a tax-exempted company incorporated in the Cayman Islands.

Broad Cosmos is tax-exempted company incorporated in the British Virgin Islands.

AN China did not have any assessable profits arising in or derived from Hong Kong for the years ended December 31, 2016, 2017 and 2018, and
accordingly no provision for Hong Kong Profits Tax was made in these years. According to Tax (Amendment) (No. 3) Ordinance 2018 published by
Hong Kong government, form April 1, 2018, under the two-tiered profits tax rates regime, the profits tax rate for the first $2 million of assessable
profits will be lowered to 8.25% (half of the rate specified in Schedule 8 to the Inland Revenue Ordinance (IRO)) for corporations and 7.5% (half of
the standard rate) for unincorporated businesses (mostly partnerships and sole proprietorships). Assessable profits above $2 million will continue to
be subject to the rate of 16.5% for corporations and standard rate of 15% for unincorporated businesses. AN China is qualified to elect the tax rate of
8.25% as it has no assessable profit in 2018.

The Group's subsidiaries in the PRC are all subject to PRC Enterprise Income Tax ("EIT") on the taxable income in accordance with the relevant
PRC income tax laws and regulations. The EIT rate for the Group's operating in PRC was 25% with the following exceptions.

Chuangyi Technology qualified for the High and New-Tech Enterprise ("HNTE") and maintained the status that would allow for a reduced 15% tax
rate under EIT Law from year 2006 to 2017. Hence, Chuangyi Technology was subject to an EIT rate of 15%, 15% and 25% in 2016, 2017, and
2018, respectively.

Xi’an  Shengshi  qualified  as  a  "Software  Enterprise"  in  August  2008  by  Technology  Information  Bureau  of  Shaanxi  province,  and  therefore  is
entitled to a two-year exemption from the EIT commencing from its first profitable year and a 50% deduction of 25% EIT rate for the succeeding
three years, with approval by the relevant tax authorities. As Xi’an Shengshi first made profit in 2009, it was exempted from EIT in 2009 and 2010,
and enjoyed the preferential income tax rate of 12.5% from 2011 to 2013. In 2014, Xi’an Shengshi qualified as HNTE and entitled to an EIT rate of
15% for the years 2014, 2015 and 2016, and Xi’an AM is subject to EIT at a rate of 25% from 2017 afterwards.

Wangfan Linghang qualified for the HNTE at the end of 2017 and entitled to an EIT rate of 15% for the years 2017, 2018 and 2019.

Beijing Yuehang Tianyi qualified for the HNTE in 2018 and entitled to an EIT rate of 15% for the years 2018, 2019 and 2020.

F-42

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

14.

INCOME TAXES - continued

Income tax expenses are as follows:

Income tax expenses:

Current
Deferred

For the years ended December 31,
2017

2016

2018

  $

  $

50    $
4,433     
4,483    $

633    $
-     
663    $

150 

150 

The principal components of the Group's deferred income tax assets and liabilities are as follows:

Deferred tax assets:

Allowance for doubtful accounts
Amortization of intangible assets
Net operating loss carry forwards
Excess marketing and advertising expense (15%)
Share transfer gain according to Tax Law
Unrealized exchange gains

Total deferred tax assets

Valuation allowance

Total deferred tax assets, net

F-43

As of December 31,

2017

2018

  $

12,270    $
1,163     
51,769     
-     
-     
-     
65,202     

14,173 
232 
69,835 
12 
(1,934)
(378)
81,940 

(65,202)    

(81,940)

  $

-    $

- 

 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
   
 
   
 
 
   
      
      
  
   
  
 
 
 
 
 
 
 
 
   
 
   
      
  
   
   
   
   
   
   
 
   
      
  
   
 
   
      
  
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

14.

INCOME TAXES - continued

The valuation allowance provided as of December 31, 2016, 2017 and 2018 relates to the deferred tax assets generated by the Group’s VIEs. The
Group periodically evaluates the likelihood of the realization of deferred tax assets, and reduces the carrying amount of the deferred tax assets by a
valuation allowance to the extent it believes that either it is more likely than not that the deferred tax assets for these entities will not be realized as it
does not expect to generate sufficient taxable income in future, or the amount involved is not significant. The Group's subsidiaries in the PRC had
total  net  operating  loss  carry  forwards  approximately  of  $302,480  as  of  December  31,  2018.  The  net  operating  loss  carry  forwards  for  the  PRC
subsidiaries will expire on various dates through year 2023.

Reconciliation between the provision for income taxes computed by applying the PRC EIT rate of 25% to income before income taxes and the actual
provision of income taxes is as follows:

For the years ended December 31,
2017

2018

2016

Net loss before provision for income taxes
PRC statutory tax rate
Income tax at statutory tax rate

Expenses not deductible for tax purpose

  $

(84,759)

  $
25%    

(21,190)

(178,548)

  $
25%    

(44,637)

(93,269)
25%
(23,317)

 Entertainment expenses exceeded the tax limit
 Tax effect of impairment loss on property and equipment and intangible assets
 Tax effect of other permanent differences

Changes in valuation allowance
Effect of preferential tax rates granted to PRC entities
Effect of income tax rate difference in other jurisdictions

158 
- 
1,688 
22,200 
642 
984 

91 
12,539 
2,482 
28,815 
670 
673 

132 
302 
4,900 
16,738 
689 
706 

Income tax expenses

Effective tax rates

  $

4,482 

  $

633 

  $

150 

(5.3)%   

(0.4)%   

(0.2)%

A valuation allowance was provided against deferred tax assets in entities where it was determined, it was more likely than not that the benefits of
the  deferred  tax  assets  will  not  be  realized.  The  Group  had  deferred  tax  assets  which  consisted  of  tax  loss  carry-forwards,  accruals  and  reserves
which can be carried forward to offset future taxable income. Management determined it is more likely that deferred tax assets could not be utilized,
so a valuation allowance was provided as of December 31, 2017 and 2018. The net valuation allowance increased by $22,200, $28,815 and $16,738
during the years ended December 31, 2016, 2017 and 2018, respectively.

F-44

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
   
 
   
  
   
  
   
  
   
  
   
  
   
  
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
 
   
  
   
  
   
  
 
   
  
   
  
   
  
   
 
  
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

14.

INCOME TAXES - continued

The  Group  incurred  penalties  of  nil,  nil  and  $4,324  related  to  underpayment  or  delayed  payment  for  income  tax  expense  for  the  years  ended
December 31, 2016, 2017 and 2018. The tax penalty of $2,664 is charged for one-year delay of income tax payment of 2015 rising from the gain on
transferring 75% equity of AM Advertising and the tax penalty of $1,660 is charged for the unpaid income tax expense of 2016 for the deduction of
bad debt allowance from taxable income before tax without chasing up for debt and filing a special declaration of loss in asset. As of December 31,
2018, all the penalties have been paid off. For the transferring 20.32% equity of AM Advertising of which the industrial and commercial registration
procedure was completed in December 2018, the Group has filed this equity transaction in the first quarter tax return filling in early 2019. For the
deduction of bad allowance, the inspection method has been changed from filing a declaration to reporting the loss by taxpayer. Hence, the Group
did not identify significant unrecognized tax benefits for the years ended December 31, 2016, 2017 and 2018.

Since  the  commencement  of  operations  in  August  2005,  only  Chuangyi  Technology  and  Shenzhen  Yuehang  have  been  subjected  to  a  tax
examination by the relevant PRC tax authorities. The Group's subsidiaries, VIEs and VIEs' subsidiaries remain subject to tax examinations at the tax
authority's  discretion.  The  Group  is  not  currently  under  examination  by  any  income  taxing  authority,  nor  has  it  been  notified  of  an  impending
examination.

Uncertainties exist with respect to how the current income tax law in the PRC applies to the Group's overall operations, and more specifically, with
regard  to  tax  residency  status.  New  EIT  Law  includes  a  provision  specifying  that  legal  entities  organized  outside  of  China  will  be  considered
residents for Chinese income tax purposes if the place of effective management or control is within China. The Implementation Rules to the new EIT
Law  provide  that  non-resident  legal  entities  will  be  considered  China  residents  if  substantial  and  overall  management  and  control  over  the
manufacturing and business operations, personnel, accounting, properties, etc., occurs within China. Additional guidance is expected to be released
by the Chinese government in the near future that may clarify how to apply this standard to tax payers. Despite the present uncertainties resulting
from the limited PRC tax guidance on the issue, the Group does not believe that its legal entities organized outside of China should be treated as
residents for new EIT Law purposes. If the PRC tax authorities subsequently determine that the Company and its subsidiaries registered outside the
PRC should be deemed resident enterprises, the Company and its subsidiaries registered outside the PRC will be subject to the PRC income tax at a
rate of 25%.

However, the Company's subsidiaries located in the PRC were in a loss position and had accumulated deficit as of December 2018, and the tax basis
for the investment was greater than the carrying value of this investment. A deferred tax asset should be recognized for this temporary difference
only if it is apparent that the temporary difference will reverse in the foreseeable future. Absent of evidence of a reversal in the foreseeable future, no
deferred tax asset for such temporary difference was recorded. The Company did not record any tax on any of the undistributed earnings because the
relevant subsidiaries do not intend to declare dividends and the Company intends to permanently reinvest it within the PRC. Additionally, deferred
tax  liability  was  recorded  for  taxable  temporary  differences  attributable  to  the  undistributed  earnings  of  VIEs  because  the  Company  believes  the
undistributed earnings can be distributed in a manner that would be subject to income tax.

Aggregate undistributed earnings of the Company's subsidiaries located in the PRC that are available for distribution to the Company are considered
to be indefinitely reinvested and accordingly, no provision has been made for the Chinese dividend withholding taxes that would be payable upon the
distribution  of  those  amounts  to  the  Company.  The  Chinese  tax  authorities  have  also  clarified  that  distributions  made  out  of  pre-January  1,  2008
retained earnings will not be subject to the withholding tax.

F-45

 
 
 
 
 
  
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

15.

NET LOSS PER SHARE

The calculation of the net loss per share is as follows:

For the years ended December 31,
2017

2016

2018

Numerator:
Net loss attributable to AirMedia Group Inc.'s ordinary shareholders

  $

(65,625)   $

(156,476)   $

(90,070)

Denominator:
Weighted average ordinary shares outstanding used in computing net loss per ordinary

share
Basic and diluted

Weighted average shares used in calculating loss per ADS
  Basic and diluted

Net loss per ordinary share

Basic and diluted

Net loss per ADS (i)
Basic and diluted

125,277,056     

125,629,779     

125,653,175 

12,527,706     

12,562,978     

12,565,318 

  $

  $

(0.52)   $

(1.25)   $

(0.72)

(5.24)   $

(12.46)   $

(7.17)

(i)

On March 29, 2019, Airmedia Group Inc., JPMorgan Chase Bank, as depositary, and all holders from time to time of American Depositary
Shares entered into Amended and Restated Deposit Agreement to combine original 5 ADSs to 1 ADSs. After the agreement is executed, 1
ADS  amounted  to  $0.01  par  value  represents  10  ordinary  shares  amounted  to  0.001  per  share  par  value.  The  Group  presents  net  loss
attributable to AirMedia Group Inc.'s ordinary shareholders per ADS by retrospectively adjusting to all periods presented.

F-46

 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
   
 
   
 
 
   
      
      
  
 
   
      
      
  
   
      
      
  
   
      
      
  
   
   
      
      
  
   
 
   
      
      
  
   
      
      
  
 
   
      
      
  
   
      
      
  
  
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

16.

SHARE BASED PAYMENTS

2012 Share incentive plan

On  November  30,  2012,  the  Board  of  Directors  adopted  2012  Share  Incentive  Plan  (the  "2012  Option  Plan"),  which  allows  the  Group  to  grant
options to its employees and directors to purchase up to 6,000,000 ordinary shares of the Company subject to vesting requirement.

On June 1 and August 1, 2014, the Group granted 2,376,620 options and 140,000 options to its employees under the 2012 Option Plan to purchase
the Company’s ordinary shares at an exercise price of $1.025 and $1.045 per share, respectively. One twelfth of these options will vest each quarter
through June 1, 2017 and August 1, 2017, respectively. The expiration date will be 5 years from the grant dates.

On October 13, 2014, an employee terminated his employment with the Group but continued to provide service as a nonemployee consultant. 50,000
options granted to him on August 1, 2014 were not modified in connection with the change in status, but future service is still necessary to earn the
award. The compensation cost was measured as if the options were newly granted at the date of the change of status. The incremental share-based
compensation expense for the year ended December 31, 2014 was not material. On October 31, 2015, the consultant service contract terminated. Of
the 50,000 options granted to him, 20,830 were vested through the service period end and the expiration date of the vested options was modified
from August 1, 2019 to January 31, 2016. The rest 29,170 unvested options were cancelled at the service period end.

F-47

 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

16.

SHARE BASED PAYMENTS - continued

2012 Share incentive plan - continued

On May 12, 2015, the Group granted 660,000 options its employees under the 2012 Option Plan to purchase the Company’s ordinary shares at an
exercise price of $1.675 per share. One twelfth of these options will vest each quarter through May 12, 2018. The expiration date will be 5 years
from the grant date.

On June 15, 2015, an employee terminated his employment with the Group but continued to provide service as a nonemployee consultant. 200,000
options granted to him on June 1, 2014 were not modified in connection with the change in status, but future service is still necessary to earn the
award. The compensation cost was measured as if the options were newly granted at the date of the change of status. The incremental share-based
compensation expense for the year ended December 31, 2015 was not material.

On  October  31,  2015,  an  employee  terminated  his  employment  with  the  Group  but  continued  to  provide  service  as  a  nonemployee  consultant.
100,000 options granted to him on May 12, 2015 were not modified in connection with the change in status, but future service is still necessary to
earn the award. The compensation cost was measured as if the options were newly granted at the date of the change of status. The incremental share-
based compensation expense for the year ended December 31, 2015 was not material.

On December 31, 2015, two consultants resigned. Of the 200,000 options granted to one of them on May 12, 2015, 3,332 were vested through her
date  of  resignation.  The  expiration  date  of  the  vested  options  was  modified  from  May  12,  2020  to  May  31,  2016.  For  the  rest  166,668  unvested
options, one twelfth of the total granted options will still vest on February 12, 2016 following the original vesting schedule and the rest 150,002
options were cancelled on the date of resignation. The fair value of the stock options, which was $1.12 per share as of the modification date, was
estimated using the Black-Scholes model. The incremental compensation cost of the modified award was immaterial for the year ended December
31,  2015.  Of  the  100,000  options  granted  to  the  other  consultant  on  May  12,  2015,  16,664  were  vested  through  her  date  of  resignation.  The
expiration date of the vested options was modified from May 12, 2020 to January 31, 2016, and the 83,336 unvested options were cancelled on the
date of resignation.

On  March  10,  2016,  Board  of  Directors  approved  to  extend  the  expiration  dates  of  the  685,000  options  from  various  original  expiration  dates  in
March and April 2016 to December 31, 2016. Modified awards are viewed as an exchange of the original award for a new award. The fair value of
the stock options of $1.67 as of the modification dates, was estimated using the Black-Scholes model. The incremental share-based compensation
expense for the year ended December 31, 2016 was not material.

On July 10, 2016, Board of Directors approved to extend the expiration dates of the 2,139,918 options from original expiration date of July 11, 2016
to December 31, 2016. Modified awards are viewed as an exchange of the original award for a new award. The fair value of the stock options of
$0.38 as of the modification dates, was estimated using the Black-Scholes model. The incremental share-based compensation expense of $79 was
recognized for the year ended December 31, 2016.

For  the  year  ended  December  31,  2016,  four  employees  terminated  their  employments  with  the  Group,  but  continued  to  provide  service  as
nonemployee  consultant.  The  options  were  not  modified  in  connection  with  the  change  in  status,  but  future  service  is  still  necessary  to  earn  the
award. The compensation cost was measured as if the options were newly granted at the date of the change of status. The incremental share-based
compensation expense of $179 was recognized for the year ended December 31, 2016.

F-48

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

16.

SHARE BASED PAYMENTS - continued

The following summary of stock option activities under the 2007, 2011 and 2012 Share incentive plans as of December 31, 2018, reflective of all
modifications is presented below:

Outstanding Options

Weighted
average
exercise
price

  Number of

options

per option    

5,868,528    $
-     
(2,500)    

1.15    $
-     
-     

5,857,755    $

1.15    $

5,857,755     

1.15     

Outstanding as of January 1, 2018
Exercised
Forfeited or expired

Outstanding as of December 31, 2018
Options vested and expected to vest as of

December 31, 2018

Weighted
average
grant-date
fair value

Weighted
average
remaining
contractual
terms

    Aggregate
intrinsic
value

1.05     
-     
-     

1.05     

1.05     

0.75    $
-     
-     

-    $

-     

-    $

- 
- 
- 

- 

- 

- 

Options exercisable as of December 31, 2018

5,857,755    $

1.15    $

1.05     

The total intrinsic value of options exercised during the years ended December 31, 2016, 2017 and 2018 were $1,928, nil and nil respectively. The
Group recorded share-based compensation of $773, $343 and $45 for the years ended December 31, 2016, 2017 and 2018, respectively. There was
$45 and nil of total unrecognized compensation expense related to unvested share options granted as of December 31, 2017 and 2018, respectively.
The expense is expected to be recognized over a weighted-average period 0.75 and 0 years on a straight-line basis as of December 31, 2017 and
2018, respectively. 

F-49

 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
 
 
   
   
   
   
 
 
 
   
   
   
 
 
 
 
   
 
   
 
   
 
   
 
 
   
   
   
 
   
      
      
      
      
  
   
   
 
   
      
      
      
      
  
   
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

16.

SHARE BASED PAYMENTS – continued

(1)

Volatility

The volatility of the underlying ordinary shares during the life of the options was estimated based on the historical stock price volatility of
the Company's ordinary shares and listed shares of comparable companies over a period comparable to the expected term of the options.
From  March  2011,  the  volatility  was  estimated  based  on  the  historical  volatility  of  the  Company's  share  price  as  the  Company  has
accumulated sufficient history of stock price for a period comparable to the expected term of the options.

(2)

Risk-free rate

Risk-free rate is based on yield of US Treasury bill as of valuation date with maturity date close to the expected term of the options.

(3)

Expected term

The expected term is estimated based on a consideration of factors including the original contractual term and the vesting term.

(4)

Dividend yield

The dividend yield was estimated by the Group based on its expected dividend policy over the expected term of the options. The Group has
no plan to pay any dividend in the foreseeable future. Therefore, the Group considers the dividend yield to be zero.

(5)

Exercise price

The exercise price of the options was determined by the Group's Board of Directors.

(6)

Fair value of underlying ordinary shares

The closing market price of the ordinary shares of the Company as of the grant/modification date was used as the fair value of the ordinary
shares on that date.

F-50

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

17.

FAIR VALUE MEASUREMENT

Measured on recurring basis

The Group measured its financial assets and liabilities, including cash and cash equivalents, accounts receivable, amounts due from related parties,
prepaid equipment costs, accounts payable and amounts to from related parties on a recurring basis as of December 31, 2017 and 2018.

Cash and cash equivalents and restricted cash are classified within Level 1 of the fair value hierarchy because they are valued based on the quoted
market  price  in  an  active  market.  The  carrying  amounts  of  accounts  receivable,  amounts  due  from  related  parties,  prepaid  equipment  cost  and
accounts payable approximate their fair values due to their short-term maturity.

Measured on non-recurring basis

The Group measured intangible assets and property and equipment at fair value on a nonrecurring basis. The fair value was determined using models
with significant unobservable inputs (Level 3 inputs). This was based on a number of key assumptions, including, but not limited to, undiscounted
future  cash  flows  and  the  annual  net  revenue  projections  based  on  the  projected  levels  of  advertising  activities  during  the  forecast  periods,  all  of
which were classified as Level 3 in the fair value hierarchy. As a result, the Group recorded $826, $67,342 and $564 impairment charged for the
years ended December 31, 2016, 2017 and 2018, respectively.

The Group measured its long-term investment in AM Advertising at fair value on a nonrecurring basis as result of the disposal transaction. The fair
value was determined using the market approach (AM Advertising’s recent capital transaction announced to the public) with unobservable inputs to
the  valuation  methodology  that  are  significant  to  the  measurement  of  the  fair  value  of  the  assets  or  liabilities  (Level  2  inputs).  The  impairment
recorded was nil, nil and $48,335 as of December 31, 2016, 2017 and 2018, respectively.

F-51

 
 
 
 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

18.

SHARE REPURCHASE PLAN

On March 21, 2011, the Board of Directors authorized the Company to repurchase up to $20,000 of its own outstanding ADSs within two years from
March 21, 2011. On September 26, 2012, the Board of Directors approved to increase the amount of the share repurchase program to $40,000 of its
own outstanding ADS and to extend the termination date of the share repurchase program to March 20, 2014.

Up to December 31, 2018, the Company had repurchased an aggregate of 1,306,486 ADSs from the open market for a total consideration of $17,400,
of which 438,137 ADSs had been cancelled and 868,349 ADSs were recorded as treasury stock. As of December 31, 2017 and 2018, accumulated
665,121  and  665,121  ADS  of  treasury  stock  have  been  reissued.  On  April  11,  2019,  upon  the  execution  of  Amended  and  Restated  Deposit
Agreement which was agreed by Airmedia Group Inc. and JPMorgan Chase Bank, as depositary, 5 original ADSs is combined to 1 new ADS. The
Group presents the number of ADSs by retrospectively adjusting to all periods presented. There were no repurchase or cancel of ADSs during the
year ended December 31, 2018

19.

MAINLAND CHINA CONTRIBUTION PLAN

Full  time  employees  of  the  Group  in  the  PRC  participate  in  a  government-mandated  multiemployer  defined  contribution  plan  pursuant  to  which
certain pension benefits, medical care, unemployment insurance, employee housing fund and other welfare benefits are provided to employees. PRC
labor regulations require the Group to accrue for these benefits based on certain percentages of the employees' income. The total contribution for
such employee benefits were $4,029, $3,256 and $3,434 for the years ended December 31, 2016, 2017 and 2018, respectively.

20.

STATUTORY RESERVES

As  stipulated  by  the  relevant  law  and  regulations  in  the  PRC,  the  Group's  subsidiaries,  VIEs  and  VIEs'  subsidiaries  in  the  PRC  are  required  to
maintain non-distributable statutory surplus reserve. Appropriations to the statutory surplus reserve are required to be made at not less than 10% of
profit after taxes as reported in the subsidiaries' statutory financial statements prepared under the PRC GAAP. Once appropriated, these amounts are
not available for future distribution to owners or shareholders. Once the general reserve is accumulated to 50% of the subsidiaries' registered capital,
the subsidiaries can choose not to provide more reserves. The statutory reserve may be applied against prior year losses, if any, and may be used for
general business expansion and production and increase in registered capital of the subsidiaries. The Group allocated no statutory reserves during the
years ended December 31, 2016, 2017 and 2018. The statutory reserves cannot be transferred to the Company in the form of loans or advances and
are not distributable as cash dividends except in the event of liquidation. 

F-52

 
 
 
 
 
  
 
 
 
 
 
 
 
 AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

21.

RESTRICTED NET ASSETS

Relevant PRC laws and regulations restrict the WFOEs, VIEs and VIEs' subsidiaries from transferring a portion of their net assets, equivalent to the
balance  of  their  paid-in-capital,  additional  paid-in-capital  and  statutory  reserves  to  the  Group  in  the  form  of  loans,  advances  or  cash  dividends.
Relevant PRC statutory laws and regulations restrict the payments of dividends by the Group's PRC subsidiaries and VIEs and VIEs' subsidiaries
from their respective retained earnings, if any, as determined in accordance with PRC accounting standards and regulations.

As of December 31, 2017, the balance of restricted net assets was $376,835, of which $159,565 was attributed to the paid-in-capital, additional paid-
in-capital and statutory reserves of the VIEs and VIEs' subsidiaries, and $217,270 was attributed to the paid in capital, additional paid-in-capital and
statutory reserves of WFOE. As of December 31, 2018, the balance of restricted net assets was $351,978, of which $146,375 was attributed to the
paid-in-capital,  additional  paid-in-capital  and  statutory  reserves  of  the  VIEs  and  VIEs'  subsidiaries,  and  $205,603  was  attributed  to  the  paid  in
capital,  additional  paid-in-capital  and  statutory  reserves  of  WFOE.  Under  applicable  PRC  laws,  loans  from  PRC  companies  to  their  offshore
affiliated entities require governmental approval, and advances by PRC companies to their offshore affiliated entities must be supported by bona fide
business transactions.

22.

COMMITMENTS

(a)

Operating leases

The Group has entered into operating lease agreements principally for its office spaces in the PRC. These leases expire through 2021 and
are  renewable  upon  negotiation.  Rental  expenses  under  operating  leases  for  the  years  ended  December  31,  2016,  2017  and  2018  were
$1,988, $2,854 and $2,076 respectively.

Future minimum rental lease payments under non-cancellable operating leases agreements were as follows:

Year ended December 31,

2019
2020
2021
2022

F-53

  $

  $

1,085 
854 
400 
- 

2,339 

 
 
 
 
 
 
 
 
 
 
 
   
 
 
   
 
   
   
   
 
   
  
 
  
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

(b)

Concession fees

The Group has entered into concession right agreements with vendors, such airlines, trains and petroleum companies. The contract terms of
such  concession  rights  are  usually  three  to  five  years.  The  concession  rights  expire  through  2022  and  are  renewable  upon  negotiation.
Concession fees charged into statements of operations for the years ended December 31, 2016, 2017 and 2018 were $23,470, $28,559 and
$20,976 respectively.

Future minimum concession fee payments under non-cancellable concession right agreements were as follows:

Year ended December 31,

2019
2020
2021
2022

F-54

  $

13,227 
11,436 
283 
- 

  $

24,946 

 
 
 
 
 
 
 
   
 
 
   
 
   
   
   
 
   
  
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

23.

CONTINGENT LIABILITIES

(a)

Approval for non-advertising content

A majority of the digital frames and digital TV screens in the Group's network include programs that consist of both advertising content and
non-advertising  content.  On  December  6,  2007,  the  State  Administration  of  Radio,  Film  or  Television,  or  the  SARFT,  a  governmental
authority in the PRC, issued the Circular regarding Strengthening the Management of Public Audio-Video in Automobiles, Buildings and
Other Public Areas, or the SARFT Circular. According to the SARFT Circular, displaying audio-video programs such as television news,
films  and  television  shows,  sports,  technology  and  entertainment  through  public  audio-video  systems  located  in  automobiles,  buildings,
airports, bus or train stations, shops, banks and hospitals and other outdoor public systems must be approved by the SARFT. The Group
intends to obtain the requisite approval of the SARFT for the Group's non-advertising content, but the Group cannot assure that the Group
will  obtain  such  approval  in  compliance  with  this  new  SARFT  Circular,  or  at  all.  In  January  2014,  the  Group  entered  into  a  strategic
alliance with China Radio International Oriental Network (Beijing) Co., Ltd ("CRION"), which manages the internet TV business of China
International Broadcasting Network, to operate the CIBN-AirMedia channel for broadcast network TV programs to air travelers in China.
According  to  the  terms  of  the  cooperation  arrangement  with  CRION,  during  the  cooperation  period  from  March  28,  2014  to  March  27,
2024, CRION shall obtain and, from time to time, be responsible for obtaining any approval, license and consent regarding the regulation of
broadcasting and television from relevant authorities.

There is no assurance that CRION will be able to obtain or maintain the requisite approval or the Group will be able to renew the contract
with CRION when they expire. If the requisite approval is not obtained, the Group will be required to eliminate non-advertising content
from  the  programs  included  in  the  Group's  digital  frames  and  digital  TV  screens  and  advertisers  may  find  the  Group's  network  less
attractive and be unwilling to purchase advertising time slots on the Group's network. As of December 31, 2018, the Group did not record a
provision for this matter as management believes the possibility of adverse outcome of the matter is remote and any liability it may incur
would not have a material adverse effect on its consolidated financial statements. However, it is not possible for the Group to predict the
ultimate outcome and the possible range of the potential impact of failure to obtain such disclosed registrations and approvals primarily due
to the lack of relevant data and information in the market in this industry in the past.

F-55

 
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

23.

CONTINGENT LIABILITIES - continued

(b)

AM Advertising Dispute

Linghang Shengshi had served a legal letter, dated June 29, 2016 (the “Legal Letter”), on Longde Wenchuang to challenge the proposed
transfers  by  Longde Wenchuang  of  their  equity  interests  in  AM  Advertising  to  Shanghai  Golden  Bridge  InfoTech  Co.,  Ltd.  (stock  code:
603918),  a  PRC  company  with  its  shares  listed  on  the  Shanghai  Stock  Exchange  (“Golden  Bridge”).  As  of  the  date  of  the  Legal  Letter,
Linghang  Shengshi  held  24.84%  of  the  equity  interests  in  AM  Advertising.  Longde  Wenchuang  and  Culture  Center  held  28.57%  and
46.43%,  respectively,  of  the  equity  interests  in  AM  Advertising.  On  June  14,  2016,  Longde  Wenchuang  entered  into  an  equity  interest
transfer agreement with Golden Bridge to transfer 75% equity interests in AM Advertising to Golden Bridge in consideration for shares in
Golden  Bridge  (the  “Transfer”).  Neither  of  Longde  Wenchuang  sought  consent  from  Linghang  Shengshi  with  respect  to  the  Transfer  in
accordance  with  the  provisions  of  the  Company  Law  of  the  People’s  Republic  of  China  (the  “Company  Law”).  In  the  Legal  Letter,
Linghang  Shengshi  challenges  the  validity  of  the  Transfer  on  the  ground  that  it  violated  the  statutory  right  of  first  refusal  of  Linghang
Shengshi under the Company Law. Subsequent to the Group’s legal letter, Golden Bridge ceased acquisition of 75% equity interest of AM
Advertising  from  Longde  Wenchuang  and  Culture  Center.  Longde  Wenchuang  and  Culture  Center  further  dismissed  the  Group’s
representative from Co-CEO position of AM Advertising.

On  September  2,  2016,  the  Group  received  notice  (the  “September  2,  2016  Notice”)  from  the  China  International  Economic  and  Trade
Arbitration  Commission  (the  “CIETAC”)  that  the  Company,  Chuangyi  Technology,  Linghang  Shengshi  and  Mr.  Herman  Man  Guo
(collectively, the “Respondents”) were named as respondents by the Culture Center in an arbitration proceeding submitted by the Culture
Center to the CIETAC in connection with the sale by the Group of 75% equity interests in AM Advertising to Culture Center and Longde
Wenchuang  in  June  2015.  Culture  Center  seeks  specific  performance  by  the  Respondents  of  certain  obligations  under  the  transaction
documents, which include, among other things, (i) the pledge by Linghang Shengshi and Mr. Guo of their respective equity interests in AM
Advertising  to  Culture  Center  as  security  for  their  obligations  under  the  transaction  documents,  (ii)  the  use  of  best  efforts  by  the
Respondents to cooperate with the Culture Center and Longde Wenchuang to procure the listing of AM Advertising in China and (iii) the
performance  by  the  Group  and  Mr.  Guo  of  their  respective  non-compete  obligations  to  refrain  from  holding,  operating,  or  otherwise
participating in any business that is the same or substantially the same as that of AM Advertising. The Group believes the arbitration request
is without merit and intends to defend the actions vigorously. However, no assurances can be provided that the Group will prevail in this
arbitration proceeding. In response to the September 2, 2016 Notice, the Group filed a notice against Culture Center to CIETAC for their
breach of contract.

As a result of the above disputes, the Group is no longer able to exercise significant influence in operating and strategic decision of AM
Advertising  and  cannot  access  to  AM  Advertising’s  financial  information.  Accordingly,  the  Group  accounted  its  investment  in  AM
Advertising using cost method (see Note 10) as of December 31, 2016, 2017 and 2018. AM Advertising and its subsidiaries are no longer
related parties to the Group. As of December 31, 2016, the Group treated the provision for earnout commitment of $23,549 as contingent
liability and did not record any additional provision for this matter as management believes the possibility of adverse outcome of the matter
is remote and any liability it may incur would not have a material adverse effect on its consolidated financial statements. On March 28,
2018, August 23, 2018 and November 2018, a MoU and its supplemental agreements respectively, with, among others, Longde Wenchuang
and  Beijing  Cultural  Center  Construction  and  Development  Fund  (Limited  Partnership),  under  which,  among  other  things,  Linghang
Shengshi  and  Mr.  Guo  have  agreed  to  pay  or  make  available  to  AM  Advertising  on  or  prior  to  May  30,  2018  and  further  extended  to
September 30, 2018 and December 31, 2018 an aggregate of RMB304,554 which was to be discounted by the following amounts (i) the
RMB152,000 profits attributable to Linghang Shengshi, Mr. Guo and Mr. Xu for the first nine months of 2015, based on a third-party pro
forma audit report on AM Advertising; (ii) the loan of RMB88,000 in principal balance and RMB7,840 in interests; and (iii) the payment of
RMB56,714 in cash after the sale of the 20.32% equity interests in AM Advertising, which consisted of 20.18% equity interests hold by the
Group  and  0.14%  equity  interests  hold  by  Mr.  Man  Guo  and  Mr.  Qing  Xu  on  behalf  of  the  Group,  and  following  the  completion  of  the
foregoing arrangements, our obligations with respect to the profit target for 2015, the earnout provision for the first nine months of 2015
and the loans between AM Advertising and Linghang Shengshi shall be deem completed. According to the aforesaid MoU, after Linghang
Shengshi, Mr. Guo and Mr. Xu transfer all the equity interest of AM Advertising, they will cease to be shareholders of AM Advertising and
will not be able to continuously assume the obligations in connection with the profit commitment and earn out provision as a matter of fact.

As  of  December  31,  2018,  the  sale  of  the  20.32%  equity  interests  in  AM  Advertising  has  been  completed,  while  the  cash  payment  of
RMB56,714 to Longde Wenchuang and Beijing Cultural Center Construction and Development Fund (Limited Partnership) has not been
paid  yet  by  the  Group.  Upon  the  effectiveness  of  MoU,  the  Group  wrote  off  the  contingency  of  provision  for  earnout  provision,  and
recorded an actual payable of earnout provision in the amount of RMB152,554, after the deduction loan of RMB88,000 in principal balance
and RMB7,840 in interests. 

(c)

GreatView Media Dispute

On  September  29,  2018,  SINOPEC  Shanghai  Oil  Products  Company  (the  “SINOPEC  Shanghai”)  brought  before  the  district  court  of
Huangpu, Shanghai a legal action against GreatView Media and AM Advertising. As plaintiff, SINOPEC Shanghai plead to the court a) to
dissolve the advertising service agreement and supplementary agreement signed between SINOPEC Shanghai and GreatView Media; b) to
support its claim to an overdue concession fee of RMB 24,351 over the period starting from September 2009 to February 2018, which may
be  subject  to  change,  payable  by  GreatView  Media;  c)  to  support  its  claim  to  an  overdue  electricity  bill  of  RMB  2,947  over  the  period
starting  from  September  2009  to  February  2018,  which  may  be  subject  to  change,  payable  by  GreatView  Media;  d)  to  support  its  claim
holding AM Advertising liable to both the overdue concession fee and electricity bill; and e) to support its claim that the legal fees shall be
borne by the defendants. As of December 31, 2018, The Group did not record a provision for this matter as the management believes the
possibility  of  adverse  outcome  of  the  matter  is  remote  and  the  liability  it  may  incur  would  not  have  a  material  adverse  effect  on  its

 
 
 
 
 
 
 
 
 
 
 
consolidated financial statements. In February 2019, RMB 27,298 has been paid to the court by Linghang Shengshi on behalf of GreatView
Media as security of this matter, which will be returned to the Group after the case closes if the Group wins the case. As of the date of this
annual report, the Group is not able to predict the ultimate outcome and the possible range of the potential impact of failure primarily due to
the legal action has just proceeded with the first court appearance and an exchange of evidence between the plaintiff and the defendants.

F-56

  
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

24.

RELATED PARTY TRANSACTIONS

(a)

Details of outstanding balances with the Group's related parties as of December 31, 2017 and 2018 were as follows:

Amount due from related parties:

Name of related parties

Relationship

As of December 31,
2017

2018

Mambo Fiesta Limited. (1)
Shanghai Qingxuan Co.,Ltd. (1)
Global Earning Pacific Ltd. (1)
Mr. Qing Xu (2)
Mrs. Guo Rong (1)
Mrs. Li Hong (1)
Wealthy Environment Limited. (1)
AirMedia Holding Ltd. (1)
AirMedia Merger Company Ltd. (1)

  $

Entity controlled by Mr. Xu Qing
Entity controlled by Mr. Guo
Shareholder of the Company
Shareholder of the Company
Vice president of the Company
Vice president of the Company
Shareholder of the Company
Entity controlled by Mr. Guo
Entity controlled by Mr. Guo

-    $
-     
5     
968      
14     
5     
54     
540     
665     

  $

2,251    $

16 
1 
1 
- 
- 
- 
- 
- 
- 

18 

(1)

(2)

The amounts represent interest free advances to the related parties in a short-term basis for operation purpose.

The  amounts  due  from  Mr.  Qing  Xu  represents  interest  free  advances  to  the  related  party  for  personal  purpose,  which  violated
Sarbanes-Oxley Act section 402 due to the lack of internal control in term of related party borrowings, however, all the balance has
been collected in May 2018, there was no gain or loss upon settlement.

(b)

Details of transactions with the Group's related parties for the years ended December 31, 2017 and 2018 were as follows:

Transactions

Sales to Unicome AirNet.
Purchase from Beijing Eastern Airlines Media Co.,Ltd.

F-57

  For the year ended December 31, 

2017

2018

  $
  $

            -    $
-    $

78 
157 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
   
 
 
 
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
   
 
 
 
   
      
  
 
 
 
 
 
  
 
 
 
   
 
 
 
 
   
 
 
 
 
 
AIRMEDIA GROUP INC.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS - continued
FOR THE YEARS ENDED DECEMBER 31, 2016, 2017 AND 2018
(In U.S. dollars in thousands, except share and per share data)

25.

SUBSEQUENT EVENTS

On April 2, 2018, the Group sent a notification to Sinopec Sales Co., Ltd. ("Sinopec”) to terminate the cooperation on gas station media business in
advance  as  the  Group  decided  to  terminate  the  gas  station  advertising  business,  in  which  Sinopec  confirmed  the  termination  for  concession  right
since April 1, 2018.

On March 22, 2019, two parties signed the settlement agreement and agreed that 1) the Group use all the gas station media network equipment to
deduct the payables due to Sinopec except Shanghai and Henan branch. The Group's payable to Sinopec is RMB 41,450 (including RMB 35,232 for
rental, RMB 4,435 for utilities, and RMB 1,783 for interest penalty) in total and the evaluated fair value of the gas station media network equipment
is RMB 27,606; 2) the Group shall settle remaining RMB 13,844 by providing free advertising services to Sinopec in the future as settlement.

On  March  29,  2019,  Airmedia  Group  Inc.  and  JPMorgan  Chase  Bank,  as  depositary,  and  all  holders  from  time  to  time  of  American  Depositary
Shares entered into Amended and Restated Deposit Agreement to combine 5 original ADSs to 1 new ADS which is effective on April 11, 2019.
After the agreement is executed, 1 ADS amounted to $0.01 par value represents 10 ordinary shares amounted to 0.001 par value per share.

The Group announced on March 28, 2018 and further updated on September 28, 2018 that Mr. Herman Man Guo intended to purchase AirMedia’s
ordinary shares in the form of ADSs with an aggregate value of up to $5,000 As of the date of this annual report, Mr. Herman Man Guo acquired, an
aggregate of 344,984 ADSs, representing 3,449,844 ordinary shares of the Company.

F-58

 
  
 
 
 
 
 
 
 
 
 
AIRMEDIA GROUP INC.

ADDITIONAL INFORMATION-FINANCIAL STATEMENT SCHEDULE I
FINANCIAL INFORMATION OF PARENT COMPANY
BALANCE SHEETS
(In U.S. dollars in thousands, except share and per share data)

Assets
Current assets

Cash and cash equivalents
Amount due from subsidiaries
Other current assets

Total current assets

TOTAL ASSETS

Liabilities
Current liabilities

Accrued expenses and other current liabilities

Total liabilities

Equity

Ordinary Shares ($0.001 par value; 900,000,000 shares authorized in 2017 and 2018; 127,662,057 shares and
127,697,055 shares issued as of December 31, 2017 and 2018; 125,629,779 shares and 125,664,777 shares
outstanding as of December 31, 2017 and 2018, respectively)

Additional paid-in capital
Treasury stock (2,032,278 and 2,032,278 shares as of December 31, 2017 and 2018, respectively)
Accumulated deficits
Accumulated other comprehensive income

Total equity

TOTAL LIABILITIES AND EQUITY

F-59

As of December 31,

2017

2018

  $

89    $
145,850     
1,919     

5 
51,226 
1,895 

147,858     

53,126 

  $

147,858    $

53,126 

  $

209    $

209     

1,727 

1,727 

128     
286,739     
(2,351)    
(172,318)    
35,451     

128 
284,726 
(2,351)
(262,415)
31,311 

147,649     

51,399 

  $

147,858    $

53,126 

 
 
 
 
 
 
 
 
 
   
 
   
      
  
   
      
  
   
   
 
   
      
  
   
 
   
      
  
 
   
      
  
   
      
  
   
      
  
 
   
      
  
   
 
   
      
  
   
      
  
   
   
   
   
   
 
   
      
  
   
 
   
      
  
 
 
 
AIRMEDIA GROUP INC.

ADDITIONAL INFORMATION-FINANCIAL STATEMENT SCHEDULE I
FINANCIAL INFORMATION OF PARENT COMPANY
STATEMENTS OF OPERATIONS
(In U.S. dollars in thousands)

For the years ended December 31,
2017

2016

2018

Operating expenses

Selling and marketing
General and administrative

Total operating expenses
Other income (loss), net
Investment loss in subsidiaries

  $

(8)   $
(2,356)    

(2,364)    
548     
(63,809)    

-    $
(468)    

(468)    
(5)    
(156,003)    

- 
(1,786)

(1,786)
468 
(88,779)

Net loss attributable to holders of ordinary shares

  $

(65,625)   $

(156,476)   $

(90,097)

F-60

 
 
 
 
 
 
 
 
 
   
   
 
   
      
      
  
   
 
   
      
      
  
   
   
   
 
   
      
      
  
 
 
 
AIRMEDIA GROUP INC.

ADDITIONAL INFORMATION-FINANCIAL STATEMENT SCHEDULE I
FINANCIAL INFORMATION OF PARENT COMPANY
STATEMENTS OF COMPREHENSIVE LOSS
(In U.S. dollars in thousands)

For the years ended December 31,
2017

2016

2018

Net loss
Other comprehensive loss, net of tax:

  $

(65,625)   $

(156,476)   $

(90,097)

Change in cumulative foreign currency translation adjustment

(23,220)    

35,743     

(4,140)

Comprehensive loss attributable to Parent Company

  $

(88,845)   $

(120,733)   $

(94,237)

F-61

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
   
 
   
 
 
   
      
      
  
   
 
   
      
      
  
 
 
 
AIRMEDIA GROUP INC.

ADDITIONAL INFORMATION-FINANCIAL STATEMENT SCHEDULE I
FINANCIAL INFORMATION OF PARENT COMPANY
STATEMENTS OF CHANGES IN EQUITY
(In U.S. dollars in thousands, except share and per share data)

Balance as of January 1, 2016

  124,395,645 

  $

128 

317,414 

(3,778)  

49,876 

22,928 

386,568 

Ordinary shares

Shares

  Amount  

  Additional 
paid-in
capital

Treasury
stock

(Accumulated
deficits)
retained
earnings

Accumulated
other
comprehensive
Income (loss)  

Total
equity

Stock option exercised
Share-based compensation
Foreign currency translation adjustment
Net (loss)
Acquisition of equity interests from non-controlling shareholders
Capital contribution from non-controlling interests
Balance as of December 31, 2016

Share-based compensation
Foreign currency translation adjustment
Net loss
Acquisition of equity interests from non-controlling interests
Capital contribution from non-controlling interests
Balance as of December 31, 2017

Share issued to Ascent Investor Relations LLC
Share-based compensation
Foreign currency translation adjustment
Net loss
Capital withdraw from non-controlling
Acquisition of additional equity interest in the Flying Dragon from non-

controlling interest

Balance as of December 31, 2018

1,234,134 
- 
- 
- 
- 
- 
  125,629,779 

- 
- 
- 
- 
- 
  125,629,779 

  $

  $

- 
- 
- 
- 
- 
- 
128 

- 
- 
- 
- 
- 
128 

- 
773 
- 
- 

(34,570)  
3,477 
  $ 287,094 

  $

343 
- 
- 

(1,414)  
716 
  $ 286,739 

  $

1,427 
- 
- 
- 
- 
- 
(2,351)   $

- 
- 
- 
- 
- 
(2,351)   $

(93)  
- 
- 

(65,625)  

- 
- 
(15,842)   $

- 
- 

(156,476)  

- 
- 

(172,318)   $

(23,220)  

- 
- 

1,334 
773 
(23,220)
(65,625)
(34,570)
3,477 
(292)   $ 268,737 

- 
- 
- 

- 
35,743 
- 
- 
- 
35,451 

343 
35,743 
(156,476)
(1,414)
716 
  $ 147,649 

34,998 

0.03 

- 
- 

- 
- 

18 
45 
- 
- 

(1,131)  

(945)  

- 
- 

- 

(90,097)  

(4,140)  

- 

  125,664,777 

  $

128 

  $ 284,726 

  $

(2,351)   $

(262,415)   $

31,311 

  $

18 
45 
(4,140)
(90,097)
(1,131)

(945)
51,399 

F-62

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
  
 
  
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
   
      
      
      
      
      
      
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
  
 
 
 
 
 
 
 
 
  
 
 
  
 
 
  
 
 
 
 
  
 
 
  
 
 
 
 
  
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
  
 
 
  
 
 
  
 
 
 
 
  
 
 
  
 
 
 
  
 
 
  
 
 
  
 
 
 
  
 
 
AIRMEDIA GROUP INC.

ADDITIONAL INFORMATION-FINANCIAL STATEMENT SCHEDULE I
FINANCIAL INFORMATION OF PARENT COMPANY
STATEMENTS OF CASH FLOWS
(In U.S. dollars in thousands)

CASH FLOWS FROM OPERATING ACTIVITIES

Net loss
Investment loss in subsidiaries
Share-based compensation

CHANGES IN WORKING CAPITAL ACCOUNTS

Other current assets
Accrued expenses and other current liabilities
Amount due from subsidiaries

Net cash used in operating activities

CASH FLOWS FROM FINANCING ACTIVITIES

Proceeds from exercises of stock options

Net cash provided by financing activities

Net decrease in cash
Cash, at beginning of year

Cash, at end of year

F-63

For the years ended December 31,
2018
2017
2016

  $

(65,625)   $ (156,476)   $
156,003     
63,809     
343     
773     

(90,097)
88,779 
45 

(2,456)    
(47)    
2,019     

1,907     
3     
(1,830)    

24 
1,518 
(353)

(1,527)    

(50)    

(84)

1,334     

1,334     

(193)    
332     

-     

-     

(50)    
139     

  $

139    $

89    $

- 

- 

(84)
89 

5 

 
 
 
 
 
 
 
 
 
   
   
 
   
      
      
  
   
   
 
   
      
      
  
   
      
      
  
   
   
   
 
   
      
      
  
   
 
   
      
      
  
   
      
      
  
   
 
   
      
      
  
   
 
   
      
      
  
   
   
 
   
      
      
  
 
 
 
AIRMEDIA GROUP INC.

NOTES TO ADDITIONAL INFORMATION-FINANCIAL STATEMENT SCHEDULE I
FINANCIAL INFORMATION OF PARENT COMPANY
(In U.S. dollars in thousands)

Notes:

1.

BASIS FOR PREPARATION

The condensed financial information of the parent company, AirMedia Group Inc., only has been prepared using the same accounting policies as set
out  in  the  Group's  consolidated  financial  statements  except  that  the  parent  company  has  used  equity  method  to  account  for  its  investment  in  its
subsidiaries.

2.

INVESTMENTS IN SUBSIDIARIES AND VARIABLE INTEREST ENTITIES

The  Company,  its  subsidiaries,  its  VIEs  and  VIEs'  subsidiaries  are  included  in  the  consolidated  financial  statements  where  the  inter-company
balances and transactions are eliminated upon consolidation. For the purpose of the Company's stand-alone financial statements, its investments in
subsidiaries, VIEs and VIEs' subsidiaries are reported using the equity method of accounting. The Company's share of income and losses from its
subsidiaries,  VIEs  and  VIEs'  subsidiaries  is  reported  as  earnings  from  subsidiaries,  VIEs  and  VIEs'  subsidiaries  in  the  accompanying  condensed
financial information of parent company.

3.

INCOME TAXES

The Company is a tax exempted company incorporated in the Cayman Islands.

F-64

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 4.55

Supplementary Agreement for the Memorandum Regarding Continued Implementation of the Agreement on Equity Transfer of AirMedia Group
Co., Ltd. and Its Supplementary Agreement

The Supplementary Agreement was signed by the following parties in Beijing, China on November 2018.

1. AirMedia Group Inc. (hereinafter referred to as “AirMedia”), a company duly incorporated and validly existing under the laws of Cayman and listed at
NASDAQ, the United States, with the Nasdaq code of AMCN.

2. Hangmei United Media Technology (Beijing) Co., Ltd. (hereinafter referred to as “Hangmei Technology” and now renamed as Yuehang Chuangyi Media
Technology (Beijing) Co., Ltd.), a limited liability company duly incorporated and validly existing under the laws of China with the unified social credit code
of 911100007795059762, address of Room 3088, Building 1, Yard 2, Hengfu Middle Street, Science City, Fengtai District, Beijing, and legal representative
of Herman Man Guo.

3.  Beijing  Hangmei  Shengshi  Advertising  Co.,  Ltd.  (hereinafter  referred  to  as  “Hangmei  Shengshi”  and  now  renamed  as  Beijing  Linghang  Shengshi
Advertising  Co.,  Ltd.),  a  limited  liability  company  duly  incorporated  and  validly  existing  under  the  laws  of  China  with  the  unified  social  credit  code  of
91110102801743998D, address of Room 1-0363, 1F, Building 22, Xuanwumen East Street, Xuanwu District, Beijing, and legal representative of Herman
Man Guo.

4. Herman Man Guo, a Chinese citizen with the ID number of 11010219630504 1171 and address of Room 1-3, 5F, Door 2, Building 3, Beipingli, Capital
International Airport Area, Chaoyang District, Beijing, post code: 100621.

5. Qing Xu, a Chinese citizen with the ID number of 11010119610220531 and address of Room 204, Building 5, Xibahe Xili, Chaoyang District, Beijing.

6. Beijing Longde Wenchuang Investment Fund Management Co., Ltd. (hereinafter referred to as “Longde Wenchuang”), a limited liability company duly
incorporated and validly existing under the laws of China with the unified social credit code of 91110101098266260N, address of Room 11116, Building 37,
No. 11 Hepingli East Street, Dongcheng District, Beijing, and legal representative of Xing Hongwang.

7. Beijing Cultural Center Development Fund (limited partnership) (hereinafter referred to as “Cultural Center Fund”), a limited partnership company duly
incorporated and validly existing under the laws of China with the unified social credit code of 91110000355272910P and registered address of Room 801-19,
Building  52,  No.  2  Jingyuan  North  Street,  Beijing  Economic-Technological  Development  Area,  Beijing,  and  executive  partner  of  Beijing  Cultural  Center
Development Fund Management Co., Ltd.

8. AirMedia Group Co., Ltd. (hereinafter referred to as “AirMedia Group”), a limited liability company duly incorporated and validly existing under the laws
of China with the unified social credit code of 91110000783246583E, address of Room 1901, Yanxiang Hotel, 2A Jiangtai Road, Chaoyang District, Beijing,
and legal representative of Ji Lianqiang.

 
 
 
 
 
 
 
 
 
 
 
WHEREAS, the above-mentioned parties signed the Memorandum Regarding Continued Implementation of the Agreement on Equity Transfer of AirMedia
Group  Co.,  Ltd.  and  Its  Supplementary  Agreement  (hereinafter  referred  to  as  the  “Memorandum”)  in  Beijing,  China,  on  March  28,  2018. After  friendly
negotiation, the parties have supplemented the following provisions for the specific implementation of the Memorandum:

1. It is mutually agreed that the deadline to settlements stipulated in Article 1 of the memorandum effected on March 28, 2018, which says “May 30, 2018” is
to be extended to December 31, 2018.

2. Clause 3 under Article 1 of the Memorandum stating that “Hangmei Shengshi, Herman Man Guo and Qing Xu shall make up the remaining balance of
RMB56.7139  million  after  receiving  the  first  equity  transfer  payment  for  the  sale  of  20.32%  of  the  equity  no  later  than  May  30,  2018,  and  AirMedia,
Hangmei Technology, Herman Man Guo and Qing Xu shall bear unlimited joint liability” is modified into “Hangmei Shengshi, Herman Man Guo and Qing
Xu shall make up the remaining balance of RMB56.7139 million after receiving the first equity transfer payment for the sale of 20.32% of the equity no later
than December 31, 2018, and AirMedia, Hangmei Technology, Herman Man Guo and Qing Xu shall bear unlimited joint liability”.

3. Except for the above clause, other matters stipulated in the Memorandum shall still be implemented in accordance with the original clauses.

4. This Supplemental Agreement is made in eight copies, with each party holding one copy. It has legal effect together with the Memorandum. It shall take
effect after it is signed and sealed by each party.

(There is no text below, but signature signed.)

 
 
 
 
 
 
 
 
(This page is only for the signature of the Supplementary Agreement for the Memorandum Regarding Continued Implementation of the Agreement on Equity
Transfer of AirMedia Group Co., Ltd. and Its Supplementary Agreement)

AirMedia Group Inc. 

/seal/ AirMedia Group Inc.

Yuehang Chuangyi Media Technology (Beijing) Co., Ltd. 

/seal/ Yuehang Chuangyi Media Technology (Beijing) Co., Ltd.

Legal representative or authorized representative (signature): 

/s/ Herman Man Guo

Beijing Linghang Shengshi Advertising Co., Ltd. (seal): 

/seal/Beijing Linghang Shengshi Advertising Co., Ltd.

Legal representative or authorized representative (signature): 

/s/ Herman Man Guo

Herman Man Guo (signature):

/s/ Herman Man Guo

Qing Xu (signature):

/s/ Qing Xu

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(This page is only for the signature of the Supplementary Agreement for the Memorandum Regarding Continued Implementation of the Agreement on Equity
Transfer of AirMedia Group Co., Ltd. and Its Supplementary Agreement)

Beijing Longde Wenchuang Investment Fund Management Co., Ltd. (seal): 

/seal/Beijing Longde Wenchuang Investment Fund
Management Co., Ltd.

Legal representative or authorized representative (signature):  

/s/ authorized representative

Beijing Cultural Center Development Fund (Limited Partnership) (seal):

/seal/ Beijing Cultural Center Development Fund (Limited
Partnership)

Legal representative or authorized representative (signature):

/s/ authorized representative

AirMedia Group Co., Ltd. (seal) 

/seal/ AirMedia Group Co., Ltd.

Legal representative or authorized representative (signature): 

/s/ authorized representative

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
List of the Registrant’s Significant Subsidiaries

Exhibit 8.1

Wholly-Owned Subsidiaries

1
2
3
4
5
6

Broad Cosmos Enterprises Ltd.
Air Net International Limited  
Air Net (China) Limited
Yuehang Chuangyi Technology (Beijing) Co., Ltd.
Shenzhen Yuehang Information Technology Co., Ltd.
Xi'an Shengshi Dinghong Information Technology Co., Ltd.

Affiliated Entities Consolidated in the Registrant's Financial Statements

Beijing Dongding Gongyi Advertising Co., Ltd.
Beijing GreatView Media Advertising Co., Ltd.
Guangzhou Meizheng Online Network Technology Co., Ltd.
Beijing Yuehang Tianyi Electronic Information Technology Co., Ltd.

Beijing Linghang Shengshi Advertising Co., Ltd.
Wangfan Tianxia Network Technology Co., Ltd.
Beijing Yuehang Digital Media Advertising Co., Ltd.
AirMedia Online Network Technology Group Co., Ltd.
Beijing Airnet Pictures Co., Ltd.
Beijing Zhihe Xianglong Advertising Co., Ltd.

7
8
9
10
11
12
13 Wenzhou Yuehang Advertising Co., Ltd.
14
15
16
17
18 Wangfan Linghang Mobile Network Technology Co., Ltd.
19
20
21
22 Meizheng Network Information Technology Co., Ltd.
Beijing Wangfan Jiaming Advertising Co.,Ltd.
23
Shandong Airmedia Cheweishi Network Technology Co., Ltd.
24
25
Dingsheng Ruizhi (Beiing) Investment Consulting Co., Ltd.
26 Wangfan Tongda Culture Development (Beijing) Co., Ltd.
27
28

Guangzhou Meizheng Information Technology Co., Ltd.
AirMedia Henglong Mobile Network Technology Co., Ltd.
Beijing Wangfan Jiaming Pictures Co., Ltd.

Yuehang Zhongying E-commerce Co., Ltd.
Beijing Airport United Culture Media Co., Ltd.

Place of Incorporation
British Virgin Islands
British Virgin Islands
Hong Kong
PRC
PRC
PRC

Place of Incorporation
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC
PRC

 
  
 
 
 
 
 
 
 
 
 
 
Exhibit 12.1

Certification by the Principal Executive Officer
Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

I, Herman Man Guo, certify that:

1.           I have reviewed this annual report on Form 20-F of AirMedia Group Inc.;

2.           Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to

make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this
report;

3.           Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material

respects the financial condition, results of operations and cash flows of the company as of, and for, the periods presented in this report;

4.           The company’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined
in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for
the company and have:

(a)

(b)

(c)

(d)

Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision,
to ensure that material information relating to the company, including its consolidated subsidiaries, is made known to us by others within
those entities, particularly during the period in which this report is being prepared;

Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our
supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for
external purposes in accordance with generally accepted accounting principles;

Evaluated the effectiveness of the company’s disclosure controls and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

Disclosed in this report any change in the company's internal control over financial reporting that occurred during the period covered by the
annual report that has materially affected, or is reasonably likely to materially affect, the company's internal control over financial reporting;
and

5.           The company’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting,

to the company's auditors and the audit committee of the company’s board of directors (or persons performing the equivalent functions):

(a)

(b)

All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are
reasonably likely to adversely affect the company’s ability to record, process, summarize and report financial information; and

Any fraud, whether or not material, that involves management or other employees who have a significant role in the company's internal
control over financial reporting.

Date: April 30, 2019

By:

/s/ Herman Man Guo
Name: Herman Man Guo
Title:   Chief Executive Officer

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 12.2

Certification by the Principal Financial Officer
Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

I, Xin Li, certify that:

1.           I have reviewed this annual report on Form 20-F of AirMedia Group Inc.;

2.           Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to

make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this
report;

3.           Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material

respects the financial condition, results of operations and cash flows of the company as of, and for, the periods presented in this report;

4.           The company’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures (as defined
in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)) for
the company and have:

(a)

(b)

(c)

(d)

Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision,
to ensure that material information relating to the company, including its consolidated subsidiaries, is made known to us by others within
those entities, particularly during the period in which this report is being prepared;

Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our
supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for
external purposes in accordance with generally accepted accounting principles;

Evaluated the effectiveness of the company's disclosure controls and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

Disclosed in this report any change in the company's internal control over financial reporting that occurred during the period covered by the
annual report that has materially affected, or is reasonably likely to materially affect, the company's internal control over financial reporting;
and

5.           The company’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial reporting,

to the company's auditors and the audit committee of the company’s board of directors (or persons performing the equivalent function):

(a)

(b)

All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are
reasonably likely to adversely affect the company's ability to record, process, summarize and report financial information; and

Any fraud, whether or not material, that involves management or other employees who have a significant role in the company's internal
control over financial reporting.

Date: April 30, 2019

By:

/s/ Xin Li
Name: Xin Li
Title:   Chief Financial Officer

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Certification by the Principal Executive Officer
Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

Exhibit 13.1

In connection with the Annual Report of AirMedia Group Inc. (the “Company”) on Form 20-F for the year ended December 31, 2018 as filed with
the Securities and Exchange Commission on the date hereof (the “Report”), I, Herman Man Guo, Chief Executive Officer of the Company, certify, pursuant to
18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that to my knowledge:

(1)         The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

(2)         The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the
Company.

Date: April 30, 2019

By:

/s/ Herman Man Guo
Name: Herman Man Guo
Title:   Chief Executive Officer

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Certification by the Principal Financial Officer
Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

Exhibit 13.2

In connection with the Annual Report of AirMedia Group Inc. (the “Company”) on Form 20-F for the year ended December 31, 2018 as filed with
the Securities and Exchange Commission on the date hereof (the “Report”), I, Xin Li, Chief Financial Officer of the Company, certify, pursuant to 18 U.S.C.
Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that to my knowledge:

(1)         The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

(2)         The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the
Company.

Date: April 30, 2019

By:

/s/ Xin Li
Name: Xin Li
Title:   Chief Financial Officer

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exhibit 15.1

INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM’S CONSENT

We  consent  to  the  incorporation  by  reference  in  this  Registration  Statement  of  AirMedia  Group  Inc.  on  Form  S-8  file  No.333-148352,  No.333-164219,
No.333-183448 and No. 333-187442 and on Form F-3 file No.333-161067 of our report which includes an explanatory paragraph as to the Company’s ability
to  continue  as  a  going  concern  dated  April  30,  2019,  with  respect  to  our  audits  of  the  consolidated  financial  statements  of  AirMedia  Group  Inc.  as  of
December 31, 2018 and 2017 and for the years ended December 31, 2018, 2017 and 2016 appearing in the Annual Report on Form 20-F of AirMedia Group
Inc. for the year ended December 31, 2018.

/s/ Marcum Bernstein & Pinchuk LLP

Marcum Bernstein & Pinchuk LLP
New York, New York
April 30, 2019

NEW YORK OFFICE • 7 Penn Plaza • Suite 830 • New York, New York • 10001
Phone 646.442.4845 • Fax 646.349.5200 • www.marcumbp.com

 
 
 
 
 
 
 
 
  
 
 
 
(cid:0) (cid:0) (cid:0) (cid:0) (cid:0) (cid:0) (cid:0)

Commerce & Finance Law Offices
6F NCI Tower, A12 Jianguomenwai Avenue,
Chaoyang District, Beijing, PRC; Postcode: 100022
Tel:(8610) 65693399 Fax: (8610) 65693838
Website: www.tongshang.com

Exhibit 15.2

April 30, 2019

AirMedia Group Inc.
15/F, Sky Plaza
No.46 Dongzhimenwai Street
Dongcheng District, Beijing 100027
The People’s Republic of China

Dear Sir/Madam:

We hereby consent to the reference to our firm under the headings “Item 3. Key Information—D. Risk Factor” and “Item 4. Information on the Company—B.
Business Overview” insofar as they purport to describe the provisions of PRC laws and regulations, in AirMedia Group Inc.’s Annual Report on Form 20-F
for the year ended December 31, 2018 (the “Annual Report”) filed with the Securities and Exchange Commission (the “SEC”), and further consent to the
incorporation by reference into the Registration Statements No. 333-148352, 333-164219, 333-183448 and 333-187442 on Form S-8 of AirMedia Group Inc.
of the summary of our opinions under the headings of “Item 3. Key Information—D. Risk Factor” and “Item 4. Information on the Company—B. Business
Overview.” We also consent to the filing with the SEC of this consent letter as an exhibit to the Annual Report.

Yours faithfully,

/s/ Commerce & Finance Law Offices
Commerce & Finance Law Offices

 
 
 
 
 
 
 
 
 
 
Exhibit 15.3

Our ref

MPT/629535-000001/13595511v1

AirMedia Group Inc.
15/F, Sky Plaza
No. 46 Dongzhimenwai Street
Dongcheng District
Beijing, 100027
People's Republic of China

30 April 2019

Dear Sirs

AirMedia Group Inc.

We have acted as legal advisors as to the laws of the Cayman Islands to AirMedia Group Inc., an exempted limited liability company incorporated in the
Cayman Islands (the "Company"), in connection with the filing by the Company with the United States Securities and Exchange Commission (the "SEC") of
an annual report on Form 20-F for the year ended 31 December 2018 (the "Annual Report").

We  hereby  consent  to  the  reference  of  our  name  under  the  heading  "Item  16G  Corporate  Governance"  in  the  Annual  Report,  and  further  consent  to  the
incorporation by reference into the Registration Statements No. 333-148352, 333-164219, 333-183448 and 333-187442 on Form S-8 of the Company of the
summary of our opinion under the heading of "Item 16G Corporate Governance" in the Annual Report. We also consent to the filing with the SEC of this
consent letter as an exhibit to the Annual Report.

Yours faithfully

/s/ Maples and Calder (Hong Kong) LLP
Maples and Calder (Hong Kong) LLP 

 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
Exhibit 16.1

April 30, 2019
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC20549

Dear Commissioners:

We have read Item 16F of Form 20-F of AirMedia Group Inc. (the "Company") for the year ended December 31, 2018, which the Company expects to file on
or about April 30, 2019, and have the following comments:

1. We agree with the statements made in the second and third sentences of paragraph 1, paragraphs 2 and 3, and the first sentence of paragraph 4 of

ltem 16F for which we have a basis on which to comment on, and we agree with, the disclosures.

2. We have no basis on which to agree or disagree with the statements made in the first and fourth sentences of paragraph 1, the second sentence in

paragraph 4 and entire paragraph 5 of Item 16F.

Very truly yours,

/s/ Deloitte Touche Tohmatsu Certified Public Accountants LLP
Deloitte Touche Tohmatsu Certified Public Accountants LLP
Beijing, the People's Republic of China