SEC Comment Letter 0000000000-23-008592 to GDS Holdings Ltd (GDS, GDHLF) (CIK 0001526125) (GDS)
GDS Holdings Ltd (GDS, GDHLF) (CIK 0001526125)
Date: Aug. 8, 2023 · CIK: 0001526125 · Accession: 0000000000-23-008592
AI Filing Summary & Sentiment
File numbers found in text: 001-37925
Letter
United States securities and exchange commission logo August 8, 2023 William Wei Huang Chief Executive Officer GDS Holdings Ltd F4/F5, Building C, Sunland International No. 999 Zhouhai Road Pudong, Shanghai 200137 Re:GDS Holdings Ltd Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 4, 2023 File No. 001-37925 Dear William Wei Huang: We have reviewed your August 3, 2023 response to our comment letter and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our June 27, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Notes to Consolidated Financial Statements Note 25. Major Customers and Suppliers, page F-59 1.We note your proposed revised disclosures in response to prior comment 4. Please further revise to clarify that Contracting Customer C represents the direct sales portion of revenue from End User Customer One. Also, clarify that a portion of revenue from the two significant End User Customers is also reflected within each of the Contracting Customers revenue percentages.
FirstName LastNameWilliam Wei Huang Comapany NameGDS Holdings Ltd August 8, 2023 Page 2 FirstName LastName William Wei Huang GDS Holdings Ltd August 8, 2023 Page 2 You may contact Megan Akst, Staff Staff Accountant at 202-551-3407 or Kathleen Collins, Accounting Branch Chief at 202-551-3499 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Technology cc: Daniel Ferteg
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United States securities and exchange commission logo
August 8, 2023
William Wei Huang
Chief Executive Officer
GDS Holdings Ltd
F4/F5, Building C, Sunland International
No. 999 Zhouhai Road
Pudong, Shanghai 200137
Re:GDS Holdings Ltd
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 4, 2023
File No. 001-37925
Dear William Wei Huang:
We have reviewed your August 3, 2023 response to our comment letter and have the
following comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our June 27, 2023 letter.
Form 20-F for the Fiscal Year Ended December 31, 2022
Notes to Consolidated Financial Statements
Note 25. Major Customers and Suppliers, page F-59
1.We note your proposed revised disclosures in response to prior comment 4. Please further
revise to clarify that Contracting Customer C represents the direct sales portion of revenue
from End User Customer One. Also, clarify that a portion of revenue from the two
significant End User Customers is also reflected within each of the Contracting Customers
revenue percentages.
FirstName LastNameWilliam Wei Huang
Comapany NameGDS Holdings Ltd
August 8, 2023 Page 2
FirstName LastName
William Wei Huang
GDS Holdings Ltd
August 8, 2023
Page 2
You may contact Megan Akst, Staff Staff Accountant at 202-551-3407 or Kathleen
Collins, Accounting Branch Chief at 202-551-3499 if you have questions regarding comments
on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Daniel Ferteg