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CORRESP Filing

Alibaba Group Holding Ltd
Date: Sept. 2, 2025 · CIK: 0001577552 · Accession: 0001104659-25-085888

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File numbers found in text: 333-288794

Date
September 2, 2025
Author
Alibaba Group Holding Limited
Form
CORRESP
Company
Alibaba Group Holding Ltd

Letter

Re: Alibaba Group Holding Limited

September 2, 2025

VIA EDGAR

U.S. Securities & Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3720

Attention: Mr. Brian Fetterolf

Registration Statement on Form F-4

Filed on July 21, 2025

File No. 333-288794

Ladies and Gentlemen:

Pursuant to Rule 461 of Regulation C ("Rule 461") promulgated under the Securities Act of 1933, as amended, Alibaba Group Holding Limited (the "Company") hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-4 (the "Registration Statement") be accelerated to, and that the Registration Statement become effective at, 9:00 A.M., Eastern Time on September 4, 2025, or as soon as practicable thereafter.

If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may be made by an executive officer of the Company or by any attorney from the Company's U.S. counsel, Simpson Thacher & Bartlett LLP.

The Company requests that it be notified of the effectiveness of the Registration Statement by telephone to Daniel Fertig of Simpson Thacher & Bartlett LLP at +852-2514-7660 or via email at dfertig@stblaw.com.

Very truly yours,
Alibaba Group Holding Limited

Show Raw Text
CORRESP
 1
 filename1.htm

 September 2, 2025

 VIA EDGAR

 U.S. Securities & Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549-3720

 Attention:
 Mr. Brian Fetterolf

 Re:
 Alibaba Group Holding Limited

 Registration Statement on Form F-4

 Filed on July 21, 2025

 File No. 333-288794

 Ladies and Gentlemen:

 Pursuant to Rule 461
of Regulation C ("Rule 461") promulgated under the Securities Act of 1933, as amended, Alibaba Group Holding Limited
(the "Company") hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-4 (the
 "Registration Statement") be accelerated to, and that the Registration Statement become effective at, 9:00 A.M., Eastern Time
on September 4, 2025, or as soon as practicable thereafter.

 If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may
be made by an executive officer of the Company or by any attorney from the Company's U.S. counsel, Simpson Thacher & Bartlett
LLP.

 The Company requests that
it be notified of the effectiveness of the Registration Statement by telephone to Daniel Fertig of Simpson Thacher & Bartlett
LLP at +852-2514-7660 or via email at dfertig@stblaw.com.

 Very truly yours,

 Alibaba Group Holding Limited

 By:
 /s/ Kevin Jinwei ZHANG

 Name:
 Kevin Jinwei ZHANG

 Title:
 Company Secretary