SEC Company Response from BIT Mining Ltd (BTCM) (CIK 0001517496) (SLAIY) — Aug 31, 2015
BIT Mining Ltd (BTCM) (CIK 0001517496)
Date: Aug. 31, 2015 · CIK: 0001517496 · Accession: 0001144204-15-052818
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36206
Referenced dates: August 21, 2015
Letter
Simpson Thacher & Bartlett
ICBC Tower, 35th Floor
3 Garden Road
Hong Kong
(852) 2514-7600
___________________
Facsimile (852) 2869-7694
Direct Dial Number
+852-2514-7650
E-Mail Address
CLIN@stblaw.com
August 31, 2015
VIA EDGAR
Office of Transportation and Leisure
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Mr. John Dana Brown, Attorney Advisor
Mr. Donald E. Field, Attorney Advisor
Re: 500.com Limited
Form 20-F for Fiscal Year Ended December 31, 2014
Filed April 27, 2015
File No. 001-36206
Gentlemen:
On behalf of our client, 500.com Limited, a company organized under the laws of the Cayman Islands (the “Company”), we are transmitting this letter in response to the comment received from the Staff (the “Staff”) of the Securities and Exchange Commission contained in the Staff’s letter dated August 21, 2015 (the “Comment Letter”), with respect to the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2014 (File No. 001-36206).
Set forth below is the Company’s response to the Staff’s comment in the Comment Letter. The Staff’s comment is retyped below for your ease of reference and are followed by the Company’s response.
* * * * *
Leiming Chen Daniel Fertig Adam C. Furber Anthony D. King Celia C.L. Lam Chris K.H. Lin Jin Hyuk Park Kathryn King Sudol Christopher K.S. Wong
Resident Partners
Simpson Thacher & Bartlett, Hong Kong is an affiliate of Simpson Thacher & Bartlett LLP with offices in:
New York Beijing Houston London Los Angeles Palo Alto São Paulo Seoul Tokyo Washington, D.C.
Simpson Thacher & Bartlett
General
1. In January 2015, the Ministry of Commerce of China released a discussion draft of proposed legislation for public comment, which appears to set out a plan for overhauling Chinese foreign investment laws. To the extent that the discussion draft may be material to you or your operations please disclose the discussion draft, including how the proposed changes may impact your operations. In this regard, we note that neither the Risk Factors section on page 6 nor the Regulation of Our Industry section on page 54 reference or discuss this new proposed legislation.
The Company acknowledges the Staff’s comment and respectfully advises the Staff that it will disclose the referenced draft legislation, how the proposed regulatory changes may impact its operations, and any recent developments with respect to the draft legislation in the Company’s next annual report on Form 20-F.
* * * * *
Simpson Thacher & Bartlett
If you have any questions regarding this letter, please do not hesitate to contact me at +(852) 2514-7650 (work) or clin@stblaw.com (email).
Very truly yours,
/s/ Chris K.H. Lin
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Simpson Thacher & Bartlett
ICBC Tower, 35th Floor
3 Garden Road
Hong Kong
(852) 2514-7600
___________________
Facsimile (852) 2869-7694
Direct Dial Number
+852-2514-7650
E-Mail Address
CLIN@stblaw.com
August 31, 2015
VIA EDGAR
Office of Transportation and Leisure
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Mr. John Dana Brown, Attorney Advisor
Mr. Donald E. Field, Attorney Advisor
Re:
500.com Limited
Form 20-F for Fiscal Year Ended December 31, 2014
Filed April 27, 2015
File No. 001-36206
Gentlemen:
On behalf of our client,
500.com Limited, a company organized under the laws of the Cayman Islands (the “Company”), we are transmitting this
letter in response to the comment received from the Staff (the “Staff”) of the Securities and Exchange Commission contained
in the Staff’s letter dated August 21, 2015 (the “Comment Letter”), with respect to the Company’s annual
report on Form 20-F for the fiscal year ended December 31, 2014 (File No. 001-36206).
Set forth below is
the Company’s response to the Staff’s comment in the Comment Letter. The Staff’s comment is retyped below
for your ease of reference and are followed by the Company’s response.
* * * * *
Leiming
Chen Daniel Fertig Adam C. Furber Anthony
D. King Celia C.L. Lam Chris K.H. Lin Jin
Hyuk Park Kathryn King Sudol Christopher K.S. Wong
Resident
Partners
Simpson
Thacher & Bartlett, Hong Kong is an affiliate of Simpson Thacher & Bartlett LLP with offices in:
New
York
Beijing
Houston
London
Los
Angeles
Palo
Alto
São
Paulo
Seoul
Tokyo
Washington, D.C.
Simpson Thacher & Bartlett
General
1. In January 2015, the Ministry of Commerce of China released a discussion draft of proposed legislation for public comment,
which appears to set out a plan for overhauling Chinese foreign investment laws. To the extent that the discussion draft may be
material to you or your operations please disclose the discussion draft, including how the proposed changes may impact your operations.
In this regard, we note that neither the Risk Factors section on page 6 nor the Regulation of Our Industry section on page 54 reference
or discuss this new proposed legislation.
The Company acknowledges the Staff’s
comment and respectfully advises the Staff that it will disclose the referenced draft legislation, how the proposed regulatory
changes may impact its operations, and any recent developments with respect to the draft legislation in the Company’s next
annual report on Form 20-F.
* * * * *
Simpson Thacher & Bartlett
If you have any questions regarding this
letter, please do not hesitate to contact me at +(852) 2514-7650 (work) or clin@stblaw.com
(email).
Very truly yours,
/s/ Chris K.H. Lin
Chris K.H. Lin
cc: Zhengming Pan, President
Min Yu, Chief Financial Officer