SEC Company Response from China Techfaith Wireless Communication Technology LTD (CIK 0001316317) — May 3, 2005
China Techfaith Wireless Communication Technology LTD (CIK 0001316317)
Date: May 3, 2005 · CIK: 0001316317 · Accession: 0001145549-05-000740
AI Filing Summary & Sentiment
File numbers found in text: 000-51242, 333-123921
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<TYPE>CORRESP
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<FILENAME>filename1.txt
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MERRILL LYNCH, PIERCE, FENNER & SMITH
INCORPORATED
4 World Financial Center
250 Vesey Street
New York, New York 10080
212-449-1000
(MERRILL LYNCH LOGO)
May 3, 2005
Securities and Exchange Commission
Corporate Division of Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Mr. Larry Spirgel, Assistant Director
Mr. Ted Yu, Attorney-Advisor
RE: CHINA TECHFAITH WIRELESS COMMUNICATION TECHNOLOGY LIMITED (THE "COMPANY")
REGISTRATION STATEMENT ON FORM F-1 (FILE NO. 333-123921)
Gentlemen:
As Representative of the several underwriters of the proposed initial
public offering by the Company and certain selling shareholders of American
depositary shares representing ordinary shares in the Company, we hereby join
the Company's request for acceleration of the above-referenced Registration
Statement, requesting effectiveness for 9:00 a.m. (New York time) on May 5,
2005, or as soon thereafter as is practicable.
Pursuant to Rule 460 of the General Rules and Regulations under the
Securities Act of 1933, we wish to advise you that we have effected the
following distribution of the Company's Preliminary Prospectus dated April 20,
2005, through the date hereof:
Preliminary Prospectus dated April 20, 2005:
9,642 copies to prospective underwriters, institutional investors, dealers
and others
We advise that we have complied and will continue to comply with Rule
15c2-8 under the Securities Exchange Act of 1934, including the 48-hour delivery
requirement contained in such Rule.
[Signature page follows.]
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Very truly yours,
Merrill Lynch, Pierce, Fenner & Smith Incorporated
As Representative of the several Underwriters
By: /s/ Julian Lee
----------------------------------------------
Authorized signatory
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CHINA TECHFAITH WIRELESS COMMUNICATION TECHNOLOGY LIMITED
3/F M8 WEST, NO. 1 JIU XIAN QIAO DONG ROAD
BEIJING 100016, PEOPLE'S REPUBLIC OF CHINA
May 3, 2005
VIA EDGAR AND E-MAIL
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Mr. Larry Spirgel, Assistant Director
Mr. Ted Yu, Attorney-Advisor
Re: CHINA TECHFAITH WIRELESS COMMUNICATION TECHNOLOGY LIMITED
REGISTRATION STATEMENT ON FORM F-1 (REGISTRATION NO. 333-123921)
REGISTRATION STATEMENT ON FORM 8-A (REGISTRATION NO. 000-51242)
Dear Mr. Spirgel and Mr. Yu:
Pursuant to Rule 461 of Regulation C promulgated under the Securities Act
of 1933, as amended, China Techfaith Wireless Communication Technology Limited
(the "Company") hereby requests that the effective date of the above-referenced
Registration Statement on Form F-1 be accelerated to, and that such Registration
Statement be declared effective on May 5, 2005 at 9:00 a.m., New York Time, or
as soon thereafter as practicable, unless we or our US counsel, Latham & Watkins
LLP, request by telephone that such Registration Statement be declared effective
at some other time.
The Company also requests that the Registration Statement on Form 8-A under
the Securities Exchange Act of 1934, as amended, covering the American
depositary shares representing ordinary shares of the Company be declared
effective concurrently with the above-captioned Registration Statement on F-1.
The Company hereby acknowledges the following:
o should the Securities and Exchange Commission (the "Commission") or the
staff of the Commission (the "Staff"), acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
o the action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Company
from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and
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o the Company may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal securities laws
of the United States.
(Signature Page to Follow)
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Very truly yours,
China Techfaith Wireless Communication
Technology Limited
By: /s/ Defu Dong
------------------------------------
Name: Defu Dong
Title: Chairman and Chief Executive Officer
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