With reference to your query below, we would like to advise that it is not a requirement under the GEM Listing Rules or other regulations/ guidelines that the placees must be professional investors. Unless the issuer intends to seek exemption from the requirement of prospectus registration under the Companies (Winding Up and Miscellaneous Provisions) Ordinance (Chapter 32), such as by way of an offer of shares to professional investors within the meaning of SFO, the proposed placing can be made to professional investors, institutional investors and other investors (such as retail investors).