SEC Comment Letter for Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552) (BABA) — Oct 11, 2017

Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552)
Date: Oct. 11, 2017 · CIK: 0001577552 · Accession: 0000000000-17-035916

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Referenced dates: September 7, 2017

Date

December 31, 2016

Author

/s/ Cecilia Blye

Form

UPLOAD

Company

Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552)

Letter

Mail Stop 4628 October 10 , 201 7 Via E-Mail Daniel Yong Zhang Chief Executive Officer Alibaba Group Holding Limited c/o Alibaba Group Services Limited 26/F Tower One, Times Square One Matheson Street, Causeway Bay Hong Kong

Re: Alibaba Group Holding Limited Form 20-F for the Fiscal Year Ended December 31, 2016 Filed June 15 , 2017 File No. 1-36614

Dear Mr. Zhang :

We refer you to our comment letter dated September 7, 2017 regarding business contacts with Sudan and Syria . We have completed our review of this subject matter. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comm ents, action or absence of action by the staff .

Sincerely,
/s/ Cecilia Blye

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Mail Stop 4628

October 10 , 201 7

Via E-Mail
Daniel Yong Zhang
Chief Executive Officer
Alibaba Group Holding Limited
c/o Alibaba Group Services Limited
26/F Tower One, Times Square
One Matheson Street, Causeway Bay
Hong Kong

 Re: Alibaba Group Holding Limited
  Form 20-F for the Fiscal  Year Ended December 31, 2016
  Filed June 15 , 2017
File No. 1-36614

Dear Mr. Zhang :

We refer you to our comment letter  dated  September 7, 2017  regarding business contacts
with Sudan and Syria .  We have completed our review of this subject matter.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comm ents, action or absence of action by the staff .

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Timothy A. Steinert
General Counsel and Secretary
Alibaba Group Holding Limited

Kevin Zhang
Legal Department
Alibaba Group Holding Limited

  Mara Ransom
  Assistant Director

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