SEC Comment Letter for TCTM Kids IT Education Inc. (VSA) (CIK 0001592560) (VSA) — Jan 28, 2014
TCTM Kids IT Education Inc. (VSA) (CIK 0001592560)
Date: Jan. 28, 2014 · CIK: 0001592560 · Accession: 0000000000-14-004324
AI Filing Summary & Sentiment
Reasoning
Referenced dates: January 15, 2014
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 -4546 DIVISION OF CORPORATION FINANCE January 1 7, 2014 Ms. Z. Julie Gao Skadden, Arps, Slate, Meagher, Flom 42/F Edinburgh Tower, The Landmark 15 Queen’s Road Central Hong Kong
Re: Tarena International, Inc. (the Company) Draft Registration Statement on Form F -1
Dear M s. Gao,
In your letter dated January 1 5, 201 4, you request on behalf of the Company that the staff waive the requirement of Item 8.A.4 of Form 20 -F to include audited financial statements of the Company as of a date not older than 12 months at the time the registration statement is filed, with respec t to the Company's registration statement to be filed on Form F -1 for the registration of its class A ordinary shares .
Your letter acknowledge s that the Company must still comply with the requirement of Item 8.A.4 of Form 20 -F to include audited financial statements not older than 15 months at the time the registration statement is declared effective.
Based on the information in your letter, the staff wil l waive the requirement to include audited financial statements of the Company as of a date not older than 12 months at the time the registration statement is filed, provided that the Company does not file your letter dated January 15, 2014 as an exhibit to its registration statement and instead files the representations specified by Instruction 2 to Item 8.A.4 of Form 20 -F as an exhibit to the registration statement.
The staff ’s conclusion is based solely on the information included in your letter. Differe nt or additional material information could lead to a different conclusion. If you have any questions regarding this letter, please call me at (202) 551 -3683.
Sincerely,
/s/ Carlos Pacho for
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -4546
DIVISION OF
CORPORATION FINANCE
January 1 7, 2014
Ms. Z. Julie Gao
Skadden, Arps, Slate, Meagher, Flom
42/F Edinburgh Tower, The Landmark
15 Queen’s Road
Central Hong Kong
Re: Tarena International, Inc. (the Company)
Draft Registration Statement on Form F -1
Dear M s. Gao,
In your letter dated January 1 5, 201 4, you request on behalf of the Company that the staff
waive the requirement of Item 8.A.4 of Form 20 -F to include audited financial statements
of the Company as of a date not older than 12 months at the time the registration
statement is filed, with respec t to the Company's registration statement to be filed on
Form F -1 for the registration of its class A ordinary shares .
Your letter acknowledge s that the Company must still comply with the requirement of
Item 8.A.4 of Form 20 -F to include audited financial statements not older than 15 months
at the time the registration statement is declared effective.
Based on the information in your letter, the staff wil l waive the requirement to include
audited financial statements of the Company as of a date not older than 12 months at the
time the registration statement is filed, provided that the Company does not file your
letter dated January 15, 2014 as an exhibit to its registration statement and instead files
the representations specified by Instruction 2 to Item 8.A.4 of Form 20 -F as an exhibit to
the registration statement.
The staff ’s conclusion is based solely on the information included in your letter. Differe nt
or additional material information could lead to a different conclusion. If you have any
questions regarding this letter, please call me at (202) 551 -3683.
Sincerely,
/s/ Carlos Pacho for
Jill Davis
Associate Chief Accountant