SEC Company Response from Cheetah Mobile (CMCM) — Apr 25, 2014
Cheetah Mobile Inc.
Date: April 25, 2014 · CIK: 0001597835 · Accession: 0001193125-14-160152
AI Filing Summary & Sentiment
Letter
VIA EDGAR Division of Corporation Finance Washington, DC 20549 Re: Cheetah Mobile Inc. (formerly known as Kingsoft Internet Software Holdings Limited) CIK No. 0001597835
Dear Ms. Jacobs, Ms. Woo, Ms. Davis and Ms. Pyles:
On behalf of our client, Cheetah Mobile Inc. (formerly known as Kingsoft Internet Software Holdings Limited), a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s Amendment No. 2 to the registration statement on Form F-1 (the “Registration Statement Amendment No. 2”) via EDGAR with the Securities and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you today four courtesy copies of the Registration Statement Amendment No. 2, marked to show changes to the Company’s Amendment No. 1 to the registration statement on Form F-1 filed with the Commission on April 22, 2014. The Company has included the data to reflect recent developments in the Registration Statement Amendment No. 2.
The Company respectfully advises the staff of the Commission (the “Staff”) that it will commence the marketing activities in connection with the offering immediately and expects to request acceleration of the effectiveness of the Registration Statement on or about May 7, 2014. The Company would appreciate the Staff’s continuing support and assistance.
* * *
Securities and Exchange Commission
April 25, 2014
Page 2
If you have any questions regarding this letter or the Registration Statement Amendment No. 2, please do not hesitate to contact the undersigned by phone at +852-3740-4863 or via e-mail at julie.gao@skadden.com.
Very truly yours,
/s/ Z. Julie Gao
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AM2LTR
SKADDEN,
ARPS, SLATE, MEAGHER & FLOM
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4863
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JULIE.GAO@SKADDEN.COM
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ADEBIYI ¿
CHRISTOPHER W. BETTS
EDWARD H.P. LAM ¿*
G.S. PAUL MITCHARD QC ¿
CLIVE W. ROUGH ¿
JONATHAN B. STONE *
ALEC P. TRACY *
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IN ENGLAND & WALES)
* (ALSO
ADMITTED IN NEW YORK)
REGISTERED FOREIGN LAWYERS
WILL H. CAI (CALIFORNIA)
Z. JULIE GAO (CALIFORNIA)
BRADLEY A. KLEIN (ILLINOIS)
RORY MCALPINE (ENGLAND & WALES)
GREGORY G.H. MIAO (NEW YORK)
ALAN G. SCHIFFMAN (NEW YORK)
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15 QUEEN’S ROAD CENTRAL, HONG KONG
TEL: (852) 3740-4700
FAX: (852)
3740-4727
www.skadden.com
April 25, 2014
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VIA EDGAR
Barbara
C. Jacobs, Assistant Director
Jan Woo, Attorney-Adviser
Christine Davis, Assistant Chief Accountant
Eiko Yaoita Pyles,
Staff Accountant
Division of Corporation Finance
U.S.
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re:
Cheetah Mobile Inc.
(formerly known as Kingsoft Internet Software Holdings Limited)
CIK No. 0001597835
Dear Ms. Jacobs, Ms. Woo, Ms. Davis and Ms. Pyles:
On behalf of our client, Cheetah Mobile Inc. (formerly known as Kingsoft Internet Software Holdings Limited), a foreign private issuer
organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s Amendment No. 2 to the registration statement on Form F-1 (the “Registration Statement Amendment
No. 2”) via EDGAR with the Securities and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you today four courtesy copies of the Registration Statement Amendment
No. 2, marked to show changes to the Company’s Amendment No. 1 to the registration statement on Form F-1 filed with the Commission on April 22, 2014. The Company has included the data to reflect recent developments in the
Registration Statement Amendment No. 2.
The Company respectfully advises the staff of the Commission (the “Staff”)
that it will commence the marketing activities in connection with the offering immediately and expects to request acceleration of the effectiveness of the Registration Statement on or about May 7, 2014. The Company would appreciate the
Staff’s continuing support and assistance.
*
* *
Securities and Exchange Commission
April 25, 2014
Page 2
If you have any questions regarding this letter or the Registration Statement Amendment No. 2, please do not hesitate to contact the
undersigned by phone at +852-3740-4863 or via e-mail at julie.gao@skadden.com.
Very truly yours,
/s/ Z. Julie Gao
Z. Julie Gao
cc:
Jun Lei, Chairman, Cheetah Mobile Inc.
Sheng Fu, Chief Executive Officer, Cheetah Mobile Inc.
Andy Yeung, Chief Financial Officer, Cheetah Mobile Inc.
King Li, Partner, Ernst & Young Hua Ming LLP
James C. Lin, Partner, Davis Polk & Wardwell LLP