Correspondence 0001213900-24-065545 from Asahi Kasei Corp (CIK 0001446531)
Asahi Kasei Corp (CIK 0001446531)
Date: Aug. 6, 2024 · CIK: 0001446531 · Accession: 0001213900-24-065545
AI Filing Summary & Sentiment
Referenced dates: August 2, 2024
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CORRESP
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AMERICAS
NEW YORK
SAN FRANCISCO
SÃO PAULO
SILICON VALLEY
WASHINGTON, D.C.
ASIA
BEIJING
HONG KONG
SEOUL
D: +1 212-225-2704
abrenneman@cgsh.com
EUROPE & MIDDLE EAST
ABU DHABI
BRUSSELS
COLOGNE
FRANKFURT
LONDON
MILAN
PARIS
ROME
Cleary,
Gottlieb, Steen & Hamilton LLP
One
Liberty Plaza
New
York, New York 10006
TEL +1 212-225-2704
Adam
brenneman
EMAIL: abrenneman@cgsh.com
August 6, 2024
Via EDGAR Correspondence
United States Securities and Exchange Commission
Division of Corporation
Finance
Office of Mergers and
Acquisitions
Attention:
Blake Grady
Washington, D.C. 20549-4561
Re: Asahi
Kasei Corporation
Calliditas Therapeutics AB
Schedule TO-T/A filed August 1, 2024 by Asahi Kasei
Corporation File No. 005-91523
Dear Mr. Grady:
On behalf of our client, Asahi Kasei Corporation,
a Japanese corporation, we respectfully acknowledge receipt of the comment of the Staff of the Division of Corporation Finance of the
Securities and Exchange Commission, with respect to the Buyer’s Schedule TO-T/A filed on August 1, 2024 (File No. 005-91523),
contained in your comment letter dated August 2, 2024 and acknowledge that if our client decided to rely on the guidance provided in Section
II.C.5 of SEC Release No. 34-58597 (Sept. 19, 2008), it would need to revise the offer materials to comply with the conditions to reliance
on that guidance. Our client has not yet made a determination that it wishes to rely on the aforementioned guidance, but if and when it
does, we would expect to fully comply with the requirements set forth therein, and we would advise you as to how our client would satisfy
the procedural requirements to rely on it.
Sincerely,
/s/ Adam Brenneman
Name: Adam Brenneman
cc:
Shinichiro Haga
Asahi Kasei Corporation
1-1-2 Yurakucho, Chiyoda-Ku
Tokyo, Japan 100-0006
Cleary Gottlieb Steen &
Hamilton LLP or an affiliated entity has an office in each of the locations listed above.