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
Referenced dates: May 6, 2014
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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