SEC Company Response from Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552) (BABA) — Dec 31, 2019
Alibaba Group Holding Ltd (BABA, BABAF, BBAAY) (CIK 0001577552)
Date: Dec. 31, 2019 · CIK: 0001577552 · Accession: 0001104659-19-077101
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Reasoning
Letter
SIMPSON THACHER & BARTLETT
ICBC TOWER, 35TH FLOOR
3 GARDEN ROAD, CENTRAL
HONG KONG
TELEPHONE: +852-2514-7600
FACSIMILE: +852-2869-7694
DIRECT DIAL NUMBER
E-MAIL ADDRESS
+852 2514-7660
dfertig@stblaw.com
December 31, 2019
CONFIDENTIAL AND VIA EDGAR AND HAND DELIVERY
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Andrew Blume, Staff Accountant
Jennifer Thompson, Accounting Branch Chief
Re:
Alibaba Group Holding Limited
Form 20-F for the Fiscal Year Ended March 31, 2019
Filed June 5, 2019
File No. 1-36614
Ladies and Gentlemen:
On behalf of our client Alibaba Group Holding Limited (the “Company”), we are submitting this letter in response to your follow-up correspondence dated December 18, 2019 (the “December 18 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission on June 5, 2019.
In the December 18 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff when the Company will respond. The Company respectfully advises the Staff that it continues to work on its responses and that it will require additional time in order to respond fully to your letter.
The Company is therefore requesting an extension until January 17, 2020 and expects to respond no later than that date and will endeavor to respond earlier if possible.
* * *
daniel fertig adam C. furber MAKIKO HARUNARI Ian C. Ho 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 TOKYO WASHINGTON, D.C.
In the meantime, please do not hesitate to contact me at +852-2514-7660 (work) or dfertig@stblaw.com (email).
Very truly yours,
/s/ Daniel Fertig
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CORRESP 1 filename1.htm SIMPSON THACHER & BARTLETT ICBC TOWER, 35TH FLOOR 3 GARDEN ROAD, CENTRAL HONG KONG TELEPHONE: +852-2514-7600 FACSIMILE: +852-2869-7694 DIRECT DIAL NUMBER E-MAIL ADDRESS +852 2514-7660 dfertig@stblaw.com December 31, 2019 CONFIDENTIAL AND VIA EDGAR AND HAND DELIVERY Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Attention: Andrew Blume, Staff Accountant Jennifer Thompson, Accounting Branch Chief Re: Alibaba Group Holding Limited Form 20-F for the Fiscal Year Ended March 31, 2019 Filed June 5, 2019 File No. 1-36614 Ladies and Gentlemen: On behalf of our client Alibaba Group Holding Limited (the “Company”), we are submitting this letter in response to your follow-up correspondence dated December 18, 2019 (the “December 18 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission on June 5, 2019. In the December 18 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff when the Company will respond. The Company respectfully advises the Staff that it continues to work on its responses and that it will require additional time in order to respond fully to your letter. The Company is therefore requesting an extension until January 17, 2020 and expects to respond no later than that date and will endeavor to respond earlier if possible. * * * daniel fertig adam C. furber MAKIKO HARUNARI Ian C. Ho 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 TOKYO WASHINGTON, D.C. In the meantime, 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 cc: Daniel Yong Zhang, Chief Executive Officer Maggie Wei Wu, Chief Financial Officer Timothy A. Steinert, General Counsel and Secretary Alibaba Group Holding Limited 2