SEC Company Response from Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552) (BABA) — Aug 26, 2015
Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552)
Date: Aug. 26, 2015 · CIK: 0001577552 · Accession: 0001104659-15-061827
AI Filing Summary & Sentiment
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SIMPSON THACHER & BARTLETT
ICBC TOWER, 35TH FLOOR
3 GARDEN ROAD
HONG KONG
(852) 2514-7600
FACSIMILE (852) 2869-7694
DIRECT DIAL NUMBER
E-MAIL ADDRESS
+852-2514-7660
DFERTIG@STBLAW.COM
August 26, 2015
VIA EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Alibaba Group Holding Limited
Registration Statement on Form F-4
Ladies and Gentlemen:
On behalf of our client, Alibaba Group Holding Limited, a company organized under the laws of the Cayman Islands (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”), the Company’s registration statement on Form F-4 (the “Registration Statement”) relating to a proposed offer to exchange the Company’s outstanding US$8,000,000,000 aggregate principal amount of unregistered senior notes that were issued in November 2014 for a like principal amount of senior notes, which will be registered under the Securities Act.
Please note that wire transfers totaling US$929,600 in payment of the applicable filing fee relating to the Registration Statement for the indicative proposed maximum aggregate offering price of US$8,000,000,000 have been made to the Commission.
* * *
Leiming Chen Daniel Fertig Adam C. Furber Anthony D. King Celia C.L. Lam Chris K.H. Lin Jin Hyuk Park Kathryn King Sudol 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
HOUSTON
LONDON
LOS ANGELES
PALO ALTO
SÃO PAULO
SEOUL
TOKYO
WASHINGTON, D.C.
If you have any questions regarding this letter or the Registration Statement, 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
Enclosures
cc: Joseph C. Tsai, Executive Vice-chairman
Daniel Yong Zhang, Chief Executive Officer
Maggie Wei Wu, Chief Financial Officer
Timothy A. Steinert, General Counsel and Secretary
Alibaba Group Holding Limited
Leiming Chen
William H. Hinman, Jr.
Daniel N. Webb
Simpson Thacher & Bartlett LLP