SEC Company Response from Baozun Inc. (BZUN, BAZNF) (CIK 0001625414) (BZUN) — May 19, 2015
Baozun Inc. (BZUN, BAZNF) (CIK 0001625414)
Date: May 19, 2015 · CIK: 0001625414 · Accession: 0001193125-15-193207
AI Filing Summary & Sentiment
File numbers found in text: 333-203477
Letter
VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Re: Baozun Inc. Amendment No. 4 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 (the “Securities Act”), Amendment No. 4 (“Amendment No. 4”) to the Company’s Registration Statement on Form F-1 (the “Registration Statement”). We respectfully submit this letter in response to a verbal comment from the staff of the Commission (the “Staff”) on May 18, 2015.
Set forth below is the Company’s response to the Staff’s verbal comment. We have included page numbers to refer to the location in Amendment No. 4 where the language addressing the comment appears.
May 19, 2015
Page 2
Courtesy copies of this letter and the Registration Statement are being hand delivered to the Staff.
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 88
Please revise the disclosure to provide further elaborate on the reasons underlying the increase in net revenues from three months ended March 31, 2014 to the three months ended March 31, 2015.
In response to the Staff’s comment, the Company has revised the relevant disclosure on page 89 of the Registration Statement.
* * *
If you have any questions regarding this response letter or the Registration Statement, 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 Transmittal 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 Boston New Jersey Brussels New York Century City Orange County Chicago Paris Doha Riyadh Dubai Rome Düsseldorf San Diego Frankfurt San Francisco Hamburg Shanghai Hong Kong Silicon Valley Houston Singapore London Tokyo Los Angeles Washington, D.C. Madrid May 19, 2015 VIA EDGAR CONFIDENTIAL Mara L. Ransom, Assistant Director Jennifer López, Staff Attorney Jennifer Thompson, Accounting Branch Chief Lisa Sellars, Staff Accountant 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. 4 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 (the “Securities Act”), Amendment No. 4 (“Amendment No. 4”) to the Company’s Registration Statement on Form F-1 (the “Registration Statement”). We respectfully submit this letter in response to a verbal comment from the staff of the Commission (the “Staff”) on May 18, 2015. Set forth below is the Company’s response to the Staff’s verbal comment. We have included page numbers to refer to the location in Amendment No. 4 where the language addressing the comment appears. May 19, 2015 Page 2 Courtesy copies of this letter and the Registration Statement are being hand delivered to the Staff. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 88 Please revise the disclosure to provide further elaborate on the reasons underlying the increase in net revenues from three months ended March 31, 2014 to the three months ended March 31, 2015. In response to the Staff’s comment, the Company has revised the relevant disclosure on page 89 of the Registration Statement. * * * If you have any questions regarding this response letter or the Registration Statement, 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