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SEC Comment Letter for Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552) (BABA) — May 20, 2014

Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552)
Date: May 20, 2014 · CIK: 0001577552 · Accession: 0000000000-14-025554

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: May 6, 2014

Date
May 20, 2014
Author
Tricia Armelin
Form
UPLOAD
Company
Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4546 DIVISION OF CORPORATION FINANCE May 20, 2014 Via facsimile Ms. Maggie Wei WU Alibaba Group Holding Limited 26/F Tower One, Times Square 1 Matheson Street Causeway Bay Hong Kong, S.A.R

Re: Alibaba Group Holding Limited (the “Company”) File No. 333 -195736

Dear Ms. WU , In your letter dated May 6, 2014, you request on behalf of the Company that the staff waive the requirement of Item 8.A.4 of Form 20- F to include audited financial statements of the Company as of a date not older than 12 months at the time the registration statement is filed, with respect to the Company's registration statement on Form F -1 for the registration of its ordinary shares to be represented by American depositary shares . Your letter acknowledge s that the Company must still comply with the requirement of Item 8.A.4 of Form 20- F to include audited financial statements not older than 15 months at the time the registration statement is declared effective. Based on the inform ation in your letter, the staff will waive the requirement to include audited financial statements of the Company as of a date not older than 12 months at the time the registration statement is filed . The staff ’s conclusion is based solely on the information included in your letter. Different or additional material information could lead to a different conclusion. If you have any questions regarding this letter, please call me at (202) 551 -3747.

Sincerely,
Tricia Armelin
Associate Chief Accountant

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4546

       DIVISION OF
CORPORATION FINANCE
May 20, 2014

Via facsimile
Ms. Maggie Wei WU
Alibaba Group Holding Limited
26/F Tower One, Times Square
1 Matheson Street
Causeway Bay
Hong Kong, S.A.R

Re: Alibaba Group  Holding Limited (the “Company”)
   File No. 333 -195736

Dear Ms. WU ,
 In your letter dated May 6, 2014, you request on behalf of the Company that the staff
waive the requirement of Item 8.A.4 of Form 20- F to include audited financial statements
of the  Company as of a date not older than 12 months at the time the registration
statement is filed, with respect to the Company's registration statement on Form F -1 for
the registration of its ordinary shares to be represented by American depositary shares .
 Your letter acknowledge s that the Company must still comply with the requirement of
Item 8.A.4 of Form 20- F to include audited financial statements not older than 15 months
at the time the registration statement is declared effective.
 Based on the inform ation in your letter, the staff will  waive the requirement to include
audited financial statements of the Company as of a date not older than 12 months at the time the registration statement is filed .
 The staff ’s conclusion is based solely on the information included in your letter. Different
or additional material information could lead to a different conclusion. If you have any questions regarding this letter, please call me at (202) 551 -3747.

Sincerely,

Tricia Armelin
      Associate Chief Accountant