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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

Date
October 6, 2020
Author
/s/ Drew Glover
Form
CORRESP
Company
TIM PARTICIPACOES SA (CIK 0001066116)

Letter

Office of Technology Division of Corporation Finance United States Securities and Exchange Commission 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

Show Raw Text
CORRESP
1
filename1.htm

    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