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Correspondence 0001104659-22-129709 from Alibaba Group Holding Ltd (BABA)

Alibaba Group Holding Ltd
Date: Dec. 23, 2022 · CIK: 0001577552 · Accession: 0001104659-22-129709

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File numbers found in text: 001-36614

Date
December 23, 2022
Author
/s/ Daniel Fertig
Form
CORRESP
Company
Alibaba Group Holding Ltd

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

+852-2514-7660

E-mail Address

dfertig@stblaw.com

December 23, 2022

VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

00 F Street, N.E.

Washington, D.C. 20549

Attention: Blaise Rhodes

Linda Cvrkel

Nicholas Nalbantian

Donald Field

Re: Alibaba Group Holding Ltd

Form 20-F for the Fiscal Year Ended March 31, 2022

Filed July 26, 2022

File No. 001-36614

Ladies and Gentlemen:

We are submitting this letter in response to your correspondence dated December 12, 2022 (the “December 12 Letter”) concerning the above-referenced annual report on Form 20-F that Alibaba Group Holding Limited (the “Company”) filed with the Commission on July 26, 2022.

In the December 12 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 anticipates that it will require additional time in order to respond fully to your letter.

michael j.c.M. ceulen marjory j. ding daniel fertig adam C. furber YI GAO MAKIKO HARUNARI Ian C. Ho JONATHAN HWANG anthony d. king jin hYUK park 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 Brussels Houston LONDON Los Angeles Palo Alto SÃO PAULO TOKYO Washington, D.C.

Simpson Thacher & Bartlett

December 23, 2022 -2-

The Company is therefore requesting an extension until January 11, 2023 (10 business days from the date of this request, taking into account the federal public holidays on December 26, 2022 and January 2, 2023) and expects to respond by that date.

* * * *

If you have any question regarding the responses contained in this letter, please do not hesitate to contact me at +852-2514-7660 or dfertig@stblaw.com.

Very truly yours,
/s/ Daniel Fertig

Show Raw Text
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

    +852-2514-7660

    E-mail Address

    dfertig@stblaw.com

  December 23, 2022

VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

00 F Street, N.E.

Washington, D.C. 20549

  Attention:
  Blaise Rhodes

Linda Cvrkel

Nicholas Nalbantian

Donald Field

 Re: Alibaba Group Holding Ltd

Form 20-F for the Fiscal Year Ended March
31, 2022

Filed July 26, 2022

File No. 001-36614

Ladies and Gentlemen:

We are submitting this letter in response to your
correspondence dated December 12, 2022 (the “December 12 Letter”) concerning the above-referenced annual report on
Form 20-F that Alibaba Group Holding Limited (the “Company”) filed with the Commission on July 26, 2022.

In the December 12 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 anticipates that it will require additional time in order to respond
fully to your letter.

    michael
    j.c.M. ceulen
    marjory
    j. ding
    daniel
    fertig
    adam
    C. furber
    YI
    GAO
    MAKIKO
    HARUNARI
    Ian
    C. Ho
    JONATHAN
    HWANG
    anthony
    d. king
    jin
    hYUK park
    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
    Brussels
    Houston
    LONDON
    Los
    Angeles
    Palo
    Alto
    SÃO
    PAULO
    TOKYO
    Washington,
    D.C.

    Simpson Thacher &
    Bartlett

    December 23, 2022
    -2-

The Company is therefore requesting an extension
until January 11, 2023 (10 business days from the date of this request, taking into account the federal public holidays on December 26,
2022 and January 2, 2023) and expects to respond by that date.

*      *     *     *

If you have any question regarding
the responses contained in this letter, please do not hesitate to contact me at +852-2514-7660 or dfertig@stblaw.com.

    Very truly yours,

    /s/ Daniel Fertig

    Daniel Fertig

  cc:
  Daniel Yong Zhang, Chief Executive Officer

Toby Hong Xu, Chief Financial Officer

Sara Siying Yu, General Counsel

Alibaba Group Holding Limited