SEC Comment Letter for Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552) (BABA) — Sep 15, 2014
Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552)
Date: Sept. 15, 2014 · CIK: 0001577552 · Accession: 0000000000-14-046127
AI Filing Summary & Sentiment
Reasoning
Letter
September 12 , 2014 Via E -mail Mr. Jack Yun Ma Executive Chairman Alibaba Group Holding Limited c/o Alibaba Group Services Limited 26/F Tower One, Times Square 1 Matheson Street, Causeway Bay Hong Kong
Re: Alibaba Group Holding Limited Amendment No. 6 to Registration Statement on Form F -1 Filed September 5, 2014 File No. 333 -195736
Dear Mr. Ma :
We have reviewed your registration statement and have the following comment . In our comment , we ask you to provide additional information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment applie s to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
Principal and Selling Shareholders, page 252
1. Please disclose the natural persons with voting and/or investment control over the shares held by the entities listed below.
Fengmao Investment Corporation CITIC Capital Excel Wisdom Fund, L.P. Broad Sino Developments Limited Prosperous Wintersweet (BVI) Limited Ever Green Growth Limited entities affiliated with Asia Alternatives Management LLC Pavilion Capital Fund Holdings Pte. Ltd. Li Ka Shing (Canada) Foundation Crescent Holding GmbH
Jack Yun Ma Alibaba Group Holding Limited September 12 , 2014 Page 2
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Jarrett Torno, Staff Accountant, at (202) 551 -3703 or Jennifer Thompson, Accounting Branch Chief, at (202) 551 -3737 if you have questions regarding comments on the financial statements and related matters. Please contact Lisa Kohl, Senior Attorney, at (202) 551 -3252, Dietrich King, Legal Branch Chief, at (202) 551 -3338, or me at (202) 551 -3720 with any other questions.
Sincerely,
/s/ Mara L. Ransom
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September 12 , 2014 Via E -mail Mr. Jack Yun Ma Executive Chairman Alibaba Group Holding Limited c/o Alibaba Group Services Limited 26/F Tower One, Times Square 1 Matheson Street, Causeway Bay Hong Kong Re: Alibaba Group Holding Limited Amendment No. 6 to Registration Statement on Form F -1 Filed September 5, 2014 File No. 333 -195736 Dear Mr. Ma : We have reviewed your registration statement and have the following comment . In our comment , we ask you to provide additional information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our comment applie s to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. Principal and Selling Shareholders, page 252 1. Please disclose the natural persons with voting and/or investment control over the shares held by the entities listed below. Fengmao Investment Corporation CITIC Capital Excel Wisdom Fund, L.P. Broad Sino Developments Limited Prosperous Wintersweet (BVI) Limited Ever Green Growth Limited entities affiliated with Asia Alternatives Management LLC Pavilion Capital Fund Holdings Pte. Ltd. Li Ka Shing (Canada) Foundation Crescent Holding GmbH Jack Yun Ma Alibaba Group Holding Limited September 12 , 2014 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Act of 193 3 and all applicable Securities Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. You may contact Jarrett Torno, Staff Accountant, at (202) 551 -3703 or Jennifer Thompson, Accounting Branch Chief, at (202) 551 -3737 if you have questions regarding comments on the financial statements and related matters. Please contact Lisa Kohl, Senior Attorney, at (202) 551 -3252, Dietrich King, Legal Branch Chief, at (202) 551 -3338, or me at (202) 551 -3720 with any other questions. Sincerely, /s/ Mara L. Ransom Mara L. Ransom Assistant Director cc: Via E -mail Leiming Chen, Esq. Simpson Thacher & Bartlett LLP