SEC Company Response from CHUNGHWA TELECOM CO LTD (CHT) (CIK 0001132924) (CHT) — Aug 8, 2005
CHUNGHWA TELECOM CO LTD (CHT) (CIK 0001132924)
Date: Aug. 8, 2005 · CIK: 0001132924 · Accession: 0001193125-05-159854
AI Filing Summary & Sentiment
File numbers found in text: 333-126417
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Mail Stop 0407
Re: Chunghwa Telecom Co., Ltd.
Dear Mr. Spirgel and Mr. Yu:
On behalf of Chunghwa Telecom Co., Ltd. (the “Company”), we enclose Amendment No. 4 to the above referenced Registration Statement on Form F-3 (the “Registration Statement”).
In response to the oral comments of the Staff given to me on August 5, 2005, the Company has revised the “Enforceability of Civil Liabilities” section on pages 100 and 101 of the prospectus to include a discussion on the obtaining and enforcement of judgments against the Ministry of the Transportation and Communications in the Republic of China. Baker & McKenzie, the Company’s Republic of China counsel, has today supplementally provided to the Staff a memorandum discussing the Republic of China legal issues involved.
The Compapny has also included a cross reference to the “Enforceability of Civil Liabilities” section in the disclosure about the right of investors to pursue legal remedies against the Ministry of Transportation and Communications if the offering is finally determined to be invalid or illegal under Taiwan law in “Risk Factors — Risks Relating to This Offering — We face opposition to our privatization, and this offering may be subject to legal or other challenges” on page 9.
SIMPSON THACHER & BARTLETT LLP
-2-
August 8, 2005
In addition to the changes indicated above, the enclosed Amendment No. 4 to the Registration Statement has also been amended to reflect ordinary updates to the disclosure.
The Company wishes to inform the Staff that the preliminary prospectuses to be delivered to investors will be in the form set forth in Amendment No. 4 to the Registration Statement, and accordingly, no issue of re-circulation of the preliminary prospectuses as a result of the revised disclosure will arise.
* * * *
If you have any questions or comments, please do not hesitate to contact me (telephone: 011-852-2514-7650, e-mail: clin@stblaw.com, fax: 011-852-2869-7694), Eugene Lee (telephone: 011-852-2514-7690, e-mail: elee@stblaw.com, fax: 011-852-2869-7694) or Daniel Fertig (telephone: 011-852-2514-7660, e-mail: dfertig@stblaw.com, fax: 011-852-2869-7694) of our firm.
Very truly yours,
/s/ Chris Lin
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CORRESP
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filename1.htm
Correspondence
August 8, 2005
VIA EDGAR
Re:
Chunghwa Telecom Co., Ltd.
Registration Statement on Form F-3
File No. 333-126417
Mr. Larry Spirgel
Assistant Director
Mr. Ted Yu
Staff Attorney
Division of Corporation
Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Mail Stop 0407
Dear Mr. Spirgel and Mr. Yu:
On behalf of Chunghwa Telecom Co., Ltd. (the “Company”), we enclose Amendment No. 4 to the above referenced
Registration Statement on Form F-3 (the “Registration Statement”).
In response to the oral comments of the Staff given to me on August 5, 2005, the Company has revised the “Enforceability of Civil Liabilities” section on pages 100 and 101 of the prospectus to include a
discussion on the obtaining and enforcement of judgments against the Ministry of the Transportation and Communications in the Republic of China. Baker & McKenzie, the Company’s Republic of China counsel, has today supplementally provided to
the Staff a memorandum discussing the Republic of China legal issues involved.
The Compapny has also included a cross reference to the “Enforceability of Civil Liabilities” section in the disclosure about the right of investors to pursue legal remedies against the Ministry of
Transportation and Communications if the offering is finally determined to be invalid or illegal under Taiwan law in “Risk Factors — Risks Relating to This Offering — We face opposition to our privatization, and this offering may be
subject to legal or other challenges” on page 9.
SIMPSON THACHER & BARTLETT LLP
-2-
August 8, 2005
In addition to the
changes indicated above, the enclosed Amendment No. 4 to the Registration Statement has also been amended to reflect ordinary updates to the disclosure.
The Company wishes to inform the Staff that the preliminary prospectuses to be delivered to investors will be in the form set forth in Amendment No. 4 to
the Registration Statement, and accordingly, no issue of re-circulation of the preliminary prospectuses as a result of the revised disclosure will arise.
* * * *
If you have any questions or comments, please do not hesitate to contact me (telephone: 011-852-2514-7650, e-mail:
clin@stblaw.com, fax: 011-852-2869-7694), Eugene Lee (telephone: 011-852-2514-7690, e-mail: elee@stblaw.com, fax: 011-852-2869-7694) or Daniel Fertig (telephone: 011-852-2514-7660, e-mail: dfertig@stblaw.com, fax: 011-852-2869-7694) of our
firm.
Very truly yours,
/s/ Chris Lin
Chris Lin
Enclosures
cc:
Mr. Hank Han-Chao Wang
Chunghwa Telecom Co., Ltd.
Ms. Hwa-Mei Wei
Chunghwa Telecom Co., Ltd.
William Y. Chua, Esq.
Sullivan & Cromwell LLP