Correspondence 0001104659-23-115513 from Alibaba Group Holding Ltd (BABA)
Alibaba Group Holding Ltd
Date: Nov. 8, 2023 · CIK: 0001577552 · Accession: 0001104659-23-115513
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-36614
Letter
Division of Corporation Finance Attention: Ms. Jennifer Thompson Re: Alibaba Group Holding Limited Form 20-F for Fiscal Year Ended March 31, 2023 Filed July 21, 2023 File No. 001-36614
Dear Division:
On behalf of our client, Alibaba Group Holding Limited (the “Company”), we are submitting this letter in response to your correspondence dated September 27, 2023 (the “September 27 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission on July 21, 2023.
In the September 27 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff as soon as possible when the Company will respond. On October 10, 2023, we submitted a letter on the Company’s behalf to the Staff to request an extension until October 26, 2023. On October 23, 2023, we submitted a letter on the Company’s behalf to the Staff to request an extension until November 9, 2023. The Company respectfully advises the Staff that it is still working on its responses, and given the current status of its preparation work, it will require additional time in order to respond fully to your letter.
The Company is therefore requesting a further extension until November 27, 2023.
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 ERIK P. WANG 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
Division of Corporation Finance
U.S. Securities and Exchange Commission
-2- November 8,
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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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
November 8, 2023
Confidential and via
edgar
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Ms. Jennifer Thompson
Mr. Austin Pattan
Ms. Lyn Shenk
Mr. Abe Friedman
Re: Alibaba Group Holding Limited
Form 20-F for Fiscal Year Ended March 31, 2023
Filed July 21, 2023
File No. 001-36614
Dear Division:
On behalf of our client, Alibaba Group Holding
Limited (the “Company”), we are submitting this letter in response to your correspondence dated September 27,
2023 (the “September 27 Letter”) concerning the above-referenced annual report on Form 20-F that the Company
filed with the Commission on July 21, 2023.
In the September 27 Letter, you requested
that the Company respond to the Staff’s comments within 10 business days or advise the Staff as soon as possible when the Company
will respond. On October 10, 2023, we submitted a letter on the Company’s behalf to the Staff to request an extension until
October 26, 2023. On October 23, 2023, we submitted a letter on the Company’s behalf to the Staff to request an extension
until November 9, 2023. The Company respectfully advises the Staff that it is still working on its responses, and given the current
status of its preparation work, it will require additional time in order to respond fully to your letter.
The Company is therefore requesting a further
extension until November 27, 2023.
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
ERIK
P. WANG
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
Division of Corporation
Finance
U.S. Securities and Exchange Commission
-2-
November 8,
2023
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: Eddie Yongming Wu, Chief Executive Officer
Toby Hong Xu, Chief Financial Officer
Sara Siying Yu, General Counsel
Alibaba Group Holding Limited
Ricky Shin, Partner
Daniel Chan, Partner
Cynthia Ning, Partner
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