SEC Company Response from SIFY TECHNOLOGIES LTD (SIFY) (CIK 0001094324) (SIFY) — Jan 20, 2005

SIFY TECHNOLOGIES LTD (SIFY) (CIK 0001094324)
Date: Jan. 20, 2005 · CIK: 0001094324 · Accession: 0000950134-05-000994

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AI Filing Summary & Sentiment

File numbers found in text: 333-121047

Referenced dates: January 6, 2005

Date

January 19, 2005

Author

/s/ Anthony J. Richmond

Form

CORRESP

Company

SIFY TECHNOLOGIES LTD (SIFY) (CIK 0001094324)

Letter

Re: Sify Limited Registration Statement on Form F-3, filed December 7, 2004 File No. 333-121047

<PAGE> 135 Commonwealth Drive Menlo Park, California 94025 Tel: (650) 328-4600 Fax: (650) 463-2600 www.lw.com

LATHAM & WATKINS LLP FIRM / AFFILIATE OFFICES Boston New Jersey Brussels New York Chicago Northern Virginia Frankfurt Orange County Hamburg Paris Hong Kong San Diego London San Francisco Los Angeles Silicon Valley Milan Singapore Moscow Tokyo Washington, D.C.

January 19, 2005

File No. 029938-0000 CONFIDENTIAL

Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attn: Barbara C. Jacobs, Assistant Director Office of Computers and Online Services

Form 20-F for Fiscal Year Ended March 31, 2004 File No. 0-27663

Ladies and Gentlemen:

On behalf of Sify Limited (the "Company"), we would like to further supplement its January 12, 2005 and January 13, 2005 responses to the letter dated January 6, 2005 from the staff (the "Staff") of the Securities and Exchange Commission relating to the Company's Registration Statement on Form F-3 referenced above (the "Registration Statement") and Form 20-F for the Company's fiscal year ended March 31, 2004.

Based upon information received from its depositary, the Company came to understand that it was advisable to file a new Form F-6 at this time to retain sufficient "headroom" to permit issuances related to stock options and other transactions. The depositary has subsequently informed the Company that the number of ADSs available under the current Form F-6 is more than sufficient to accommodate the issuance of ADSs to the selling shareholders listed in the Registration Statement as well as issuances related to stock options and other transactions for the foreseeable future. Accordingly, the Company no longer believes it is advisable to file a new Form F-6 at this time and has no current intention of doing so.

The Company appreciates the Staff's attention to this matter. Should the Staff have any questions regarding these responses or require further information, please contact the undersigned at (650) 463-2643 or William Davisson of this firm at (650) 463-2660.

Very truly yours,
/s/ Anthony J. Richmond

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<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>
                                        135 Commonwealth Drive
                                        Menlo Park, California 94025
                                        Tel: (650) 328-4600 Fax: (650) 463-2600
                                        www.lw.com

LATHAM & WATKINS LLP                    FIRM / AFFILIATE OFFICES
                                        Boston        New Jersey
                                        Brussels      New York
                                        Chicago       Northern Virginia
                                        Frankfurt     Orange County
                                        Hamburg       Paris
                                        Hong Kong     San Diego
                                        London        San Francisco
                                        Los Angeles   Silicon Valley
                                        Milan         Singapore
                                        Moscow        Tokyo
                                                      Washington, D.C.

January 19, 2005

                                        File No. 029938-0000
CONFIDENTIAL

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: Barbara C. Jacobs, Assistant Director
      Office of Computers and Online Services

            Re:   Sify Limited
                  Registration Statement on Form F-3, filed December 7, 2004
                  File No. 333-121047

                  Form 20-F for Fiscal Year Ended March 31, 2004
                  File No. 0-27663

Ladies and Gentlemen:

      On behalf of Sify Limited (the "Company"), we would like to further
supplement its January 12, 2005 and January 13, 2005 responses to the letter
dated January 6, 2005 from the staff (the "Staff") of the Securities and
Exchange Commission relating to the Company's Registration Statement on Form F-3
referenced above (the "Registration Statement") and Form 20-F for the Company's
fiscal year ended March 31, 2004.

      Based upon information received from its depositary, the Company came to
understand that it was advisable to file a new Form F-6 at this time to retain
sufficient "headroom" to permit issuances related to stock options and other
transactions. The depositary has subsequently informed the Company that the
number of ADSs available under the current Form F-6 is more than sufficient to
accommodate the issuance of ADSs to the selling shareholders listed in the
Registration Statement as well as issuances related to stock options and other
transactions for the foreseeable future. Accordingly, the Company no longer
believes it is advisable to file a new Form F-6 at this time and has no current
intention of doing so.

      The Company appreciates the Staff's attention to this matter. Should the
Staff have any questions regarding these responses or require further
information, please contact the undersigned at (650) 463-2643 or William
Davisson of this firm at (650) 463-2660.

                                       Very truly yours,

                                       /s/ Anthony J. Richmond

                                       Anthony J. Richmond
                                       of LATHAM & WATKINS LLP

cc:   Robert Bell, Esq. - SEC
      Sify Limited

</TEXT>
</DOCUMENT>

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