ZW Data Action Technologies Inc. — Director's Dealing 2009

Sep 23, 2009

SEC Form 3 — Initial Statement of Beneficial Ownership

Issuer: ChinaNet Online Holdings, Inc. (OTCBB:CHNT)
CIK: 0001376321
Period of Report: 2009-06-26

Reporting Person: Sun Li (10% Owner)

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock, $0.001 par value per share	7434940	Indirect

Footnotes

F1: In accordance with an Entrustment Agreement, dated June 5, 2009, by and between Rise King Investments Limited ("Rise King")
and Handong Cheng, Xuanfu Liu and Li Sun (collectively, the "Grantees"), Rise King collectively delegated to the Grantees
its direct or indirect rights as a stockholder of China Net Online Media Group Limited, CNET Online Technology Limited, Rise
King Century Technology Development (Beijing) Co., Ltd., Shanghai Borongdingsi Computer Technology Co., Ltd., Business
Opportunity Online (Beijing) Network Technology Co., Ltd. and Beijing CNET Online Advertising Co., Ltd. (collectively, the
"China Net Companies"), including the direct or indirect right to vote any equity interest in the China Net Companies, or to
designate the management of such companies. (continued in footnote 2)

F2: As a result of the delegation of authority under the Entrustment Agreement, Ms. Sun may be deemed to be a beneficial owner of
the shares of ChinaNet Online Holdings, Inc.'s common stock held by Rise King. Ms. Sun disclaims such beneficial ownership,
and this report shall not be deemed to be an admission that Ms. Sun is the beneficial owner of any such shares for any
purpose.