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SEC Comment Letter for Yum China Holdings, Inc. (YUMC) (CIK 0001673358) (YUMC) — Mar 29, 2017

Yum China Holdings, Inc. (YUMC) (CIK 0001673358)
Date: March 29, 2017 · CIK: 0001673358 · Accession: 0000000000-17-010363

AI Filing Summary & Sentiment

File numbers found in text: 333-213719

Date
March 9, 2017
Author
Not clearly detected
Form
UPLOAD
Company
Yum China Holdings, Inc. (YUMC) (CIK 0001673358)

Letter

Mail Stop 3561 March 29, 201 7 Shella Ng Chief Legal Officer Yum China Holdings, Inc. 7100 Corporate Drive Plano, TX 75024

Re: Yum China Holdings , Inc. Post-Effective Amendment No. 1 to Form S-1 Filed March 9, 2017 File No. 333-213719

Dear Ms. Ng :

We have limited our review of your post -effective amendment to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our com ments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to these comments, w e may have additional comments

Incorporation of Certain Information by Reference, page 58

1. Please incorporate by reference your Current Report on Form 8 -K filed on March 10, 2017.

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Shella Ng Yum China Holdings , Inc. March 29, 201 7 Page 2

Please contact John Stickel at (202) 551 -3324 or me at (202) 551 -3217 with any questions. Sincerely,

/s/ J. Nolan McWilliams

J. Nolan McWilliams Attorney -Advisor Office of Transportation and Leisure

cc: Paul L. Choi , Esq.

Show Raw Text
Mail Stop 3561
March  29, 201 7

Shella Ng
Chief Legal Officer
Yum China Holdings, Inc.
7100 Corporate Drive
Plano, TX 75024

Re: Yum China Holdings , Inc.
  Post-Effective Amendment No. 1 to Form  S-1
Filed  March 9, 2017
  File No. 333-213719

Dear Ms. Ng :

We have limited our review of your post -effective amendment  to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our com ments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, w e may have  additional comments

Incorporation of Certain Information by Reference, page 58

1. Please incorporate by reference your Current Report on Form 8 -K filed on March  10,
2017.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Shella Ng
Yum China Holdings , Inc.
March  29, 201 7
Page 2

 Please contact John Stickel at (202) 551 -3324 or me at (202) 551 -3217  with any
questions.
Sincerely,

 /s/ J. Nolan McWilliams

J. Nolan McWilliams
Attorney -Advisor
Office of Transportation and Leisure

cc:  Paul L. Choi , Esq.