Correspondence 0001104659-23-082608 from GDS Holdings Ltd (GDS, GDHLF) (CIK 0001526125) (GDS)
GDS Holdings Ltd (GDS, GDHLF) (CIK 0001526125)
Date: July 20, 2023 · CIK: 0001526125 · Accession: 0001104659-23-082608
AI Filing Summary & Sentiment
File numbers found in text: 001-37925
Letter
VIA EDGAR Division of Corporation Finance Attention: Mr. Dan Morris Re: GDS Holdings Limited Form 20-F for the Fiscal Year Ended December 31, 2022 Filed April 4, 2023 File No. 001-37925
Dear Division:
On behalf of our client, GDS Holdings Limited (the “Company”), we are submitting this letter in response to your correspondence dated June 27, 2023 (the “June 27 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission.
In the June 27 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff when the Company will respond. The Company respectfully requests that the Company be given an until August 3, 2023 (the tenth business day from the date hereof) and expects to respond no later than that date.
michael j.c.M. ceulen marjory j. ding daniel fertig adam C. furber YI GAO MAKIKO HARUNARI Ian C. Ho JONATHAN HWANG anthony d. king jin hYUK park ERIK P. WANG 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 Brussels Houston LONDON Los Angeles Palo Alto SÃO PAULO TOKYO Washington,D.C.
Simpson Thacher & Bartlett
Division of Corporation Finance
July 20, 2023 -2- U.S. Securities and Exchange Commission
The Company further respectfully requests that the Staff also address future correspondence to Mr. Dan Newman, the Company’s CFO (Dan.newman@gds-services.com) and Ms. Jamie Khoo, the Company’s COO (jamie@gds-services.com).
* * *
In the meantime, please do not hesitate to contact me at +852-2514-7660 (work) or dfertig@stblaw.com (email).
Very
truly yours,
/s/
Daniel Fertig
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Simpson
Thacher & Bartlett
ICBC
TOWER, 35TH FLOOR
3
GARDEN ROAD, CENTRAL
HONG
KONG
TELEPHONE:
+852-2514-7600
FACSIMILE:
+852-2869-7694
Direct
Dial Number
E-mail
Address
+852-2514-7660
dfertig@stblaw.com
July
20, 2023
VIA
EDGAR
Division
of Corporation Finance
U.S.
Securities and Exchange Commission
100
F Street, N.E.
Washington,
D.C. 20549
Attention:
Mr.
Dan Morris
Ms.
Jennifer Thompson
Ms.
Kathleen Collins
Ms.
Megan Akst
Re:
GDS
Holdings Limited
Form
20-F for the Fiscal Year Ended December 31, 2022
Filed
April 4, 2023
File
No. 001-37925
Dear
Division:
On
behalf of our client, GDS Holdings Limited (the “Company”), we are submitting this letter in response to your correspondence
dated June 27, 2023 (the “June 27 Letter”) concerning the above-referenced annual report on Form 20-F that the Company
filed with the Commission.
In
the June 27 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff
when the Company will respond. The Company respectfully requests that the Company be given an until August 3, 2023 (the tenth business
day from the date hereof) and expects to respond no later than that date.
michael
j.c.M. ceulen marjory j. ding daniel fertig adam
C. furber YI GAO MAKIKO HARUNARI Ian C. Ho JONATHAN
HWANG anthony d. king jin hYUK park ERIK P. WANG 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 Brussels Houston LONDON Los
Angeles Palo Alto SÃO PAULO TOKYO Washington,D.C.
Simpson Thacher & Bartlett
Division of Corporation Finance
July 20, 2023 -2- U.S. Securities and Exchange Commission
The
Company further respectfully requests that the Staff also address future correspondence to Mr. Dan Newman, the Company’s CFO (Dan.newman@gds-services.com)
and Ms. Jamie Khoo, the Company’s COO (jamie@gds-services.com).
* * *
In
the meantime, please do not hesitate to contact me at +852-2514-7660 (work) or dfertig@stblaw.com (email).
Very
truly yours,
/s/
Daniel Fertig
Daniel
Fertig
cc: William Wei Huang, Chief Executive Officer
Daniel Newman, Chief Financial Officer
Jamie
Khoo, Chief Operating Officer
Andy
Wenfeng Li, General Counsel and Company Secretary
GDS
Holdings Limited