SEC Company Response from Baozun Inc. (BZUN, BAZNF) (CIK 0001625414) (BZUN) — May 8, 2015
Baozun Inc. (BZUN, BAZNF) (CIK 0001625414)
Date: May 8, 2015 · CIK: 0001625414 · Accession: 0001193125-15-179883
AI Filing Summary & Sentiment
File numbers found in text: 333-203477
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549-3628 Re: Baozun Inc. Amendment No. 2 to Registration Statement on Form F-1 File No. 333-203477
Dear Ms. Ransom, Ms. López, Ms. Thompson and Ms. Sellars:
On behalf of our client, Baozun Inc., a company organized under the laws of the Cayman Islands (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, Amendment No. 2 (“Amendment No. 2”) to the Company’s Registration Statement on Form F-1 (the “Registration Statement”).
To facilitate the Staff’s review, the Company has separately delivered to the Staff today (a) four courtesy copies of Amendment No. 2, marked to show changes to Amendment No. 1 to the Registration Statement filed with the Commission on May 5, 2015 (the “May 5 Filing”) and (b) four courtesy copies of Amendment No. 2, marked to show changes to the Registration Statement filed with the Commission on April 17, 2015.
The Company has revised the May 5 Filing to include other information and data to reflect new developments since the May 5 Filing as well as generally to update the Registration Statement. The Company notes that it has included the estimated range of the offering price for its initial public offering and related disclosure in the preliminary prospectus which forms part of Amendment No. 2.
May 8, 2015
Page
If you have any questions regarding this letter or Amendment No. 2, please contact the undersigned by phone at +86 21 6101 6018 or via email at karen.yan@lw.com. Questions relating to accounting and auditing matters of the Company may also be directed to Alan Hu of Deloitte Touche Tohmatsu Certified Public Accountants LLP via email at alhu@deloitte.com.cn.
Respectfully submitted,
/s/ Karen M. Yan
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CORRESP 1 filename1.htm SEC Response Letter 26th Floor, Two ifc 8 Century Boulevard Shanghai 200120 People’s Republic of China Tel: +86.21.6101.6000 Fax: +86.21.6101.6001 www.lw.com FIRM / AFFILIATE OFFICES Abu Dhabi Milan Barcelona Moscow Beijing Munich May 8, 2015 Boston New Jersey Brussels New York Century City Orange County Chicago Paris VIA EDGAR Doha Riyadh Dubai Rome CONFIDENTIAL Düsseldorf San Diego Frankfurt San Francisco Hamburg Shanghai Mara L. Ransom, Assistant Director Hong Kong Silicon Valley Jennifer López, Staff Attorney Houston Singapore Jennifer Thompson, Accounting Branch Chief London Tokyo Lisa Sellars, Staff Accountant Los Angeles Washington, D.C. Madrid United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-3628 Re: Baozun Inc. Amendment No. 2 to Registration Statement on Form F-1 File No. 333-203477 Dear Ms. Ransom, Ms. López, Ms. Thompson and Ms. Sellars: On behalf of our client, Baozun Inc., a company organized under the laws of the Cayman Islands (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, Amendment No. 2 (“Amendment No. 2”) to the Company’s Registration Statement on Form F-1 (the “Registration Statement”). To facilitate the Staff’s review, the Company has separately delivered to the Staff today (a) four courtesy copies of Amendment No. 2, marked to show changes to Amendment No. 1 to the Registration Statement filed with the Commission on May 5, 2015 (the “May 5 Filing”) and (b) four courtesy copies of Amendment No. 2, marked to show changes to the Registration Statement filed with the Commission on April 17, 2015. The Company has revised the May 5 Filing to include other information and data to reflect new developments since the May 5 Filing as well as generally to update the Registration Statement. The Company notes that it has included the estimated range of the offering price for its initial public offering and related disclosure in the preliminary prospectus which forms part of Amendment No. 2. May 8, 2015 Page 2 If you have any questions regarding this letter or Amendment No. 2, please contact the undersigned by phone at +86 21 6101 6018 or via email at karen.yan@lw.com. Questions relating to accounting and auditing matters of the Company may also be directed to Alan Hu of Deloitte Touche Tohmatsu Certified Public Accountants LLP via email at alhu@deloitte.com.cn. Respectfully submitted, /s/ Karen M. Yan Karen M. Yan of LATHAM & WATKINS LLP Enclosures cc: Vincent Wenbin Qiu, Chief Executive Officer, Baozun Inc. Beck Chen, Chief Financial Officer, Baozun Inc. Karen M. Yan, Esq., Latham & Watkins LLP Leiming Chen, Esq., Simpson Thacher & Bartlett LLP Alan Hu, Deloitte Touche Tohmatsu Certified Public Accountants LLP