SEC Company Response from TIM PARTICIPACOES SA (CIK 0001066116) — Oct 6, 2020
TIM PARTICIPACOES SA (CIK 0001066116)
Date: Oct. 6, 2020 · CIK: 0001066116 · Accession: 0000950103-20-019771
AI Filing Summary & Sentiment
File numbers found in text: 001-39570
Referenced dates: September 23, 2020
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CORRESP
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October 6, 2020
Christine Dietz, Senior Staff Accountant
Frank Knapp, Staff Accountant
Office of Technology
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-7561
Re:
TIM S.A. (successor to TIM Participações
S.A.)
Form 20-F for the Year Ended December 31, 2019
Filed May 1, 2020
File No. of TIM S.A. (successor): 001-39570
File No. of TIM Participações S.A.
(predecessor): 1-14491
Dear Ms. Dietz and Mr. Knapp:
On behalf of TIM S.A. as successor to TIM
Participações S.A. (“TIM” or the “Company”), we acknowledge receipt by the
Company of the letter dated September 23, 2020 (the “Comment Letter”) of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “SEC”) with respect to the Annual Report on Form 20-F for
the Year Ended December 31, 2019 (the “2019 Form 20-F”) of TIM Participações S.A. filed with
the SEC on May 1, 2020, as amended.
TIM is working to respond to the Comment
Letter. However, the Company has advised us that it will require additional time to consider and respond to the Staff’s comments.
Accordingly, on behalf of TIM, we respectfully request an extension of time to respond to the Comment Letter to October 21, 2020.
We are grateful for
the Staff’s accommodation in this matter. Please do not hesitate to call me at (650) 644-5787 or Nicholas A. Kronfeld at
(212) 450-4950 with any questions you may have.
Very truly yours,
/s/ Drew Glover
Drew Glover
Via EDGAR