SEC Company Response from Yum China Holdings, Inc. (YUMC) (CIK 0001673358) (YUMC) — Oct 5, 2016
Yum China Holdings, Inc. (YUMC) (CIK 0001673358)
Date: Oct. 5, 2016 · CIK: 0001673358 · Accession: 0001104659-16-148968
AI Filing Summary & Sentiment
File numbers found in text: 333-213719
Letter
VIA EDGAR Mr. Justin Dobbie Legal Branch Chief Office of Transportation and Leisure U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Request for Acceleration
Re: Yum China Holdings, Inc. Registration Statement on Form S-1 File No. 333-213719
Dear Mr. Dobbie:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Yum China Holdings, Inc. (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form S-1 filed with the U.S. Securities and Exchange Commission (the “Commission”) on October 5, 2016 (File No. 333-213719) (as amended to date, the “Registration Statement”), be accelerated to 10 a.m., Eastern Time, on October 7, 2016, or as soon as practicable thereafter.
In connection with the foregoing request for acceleration of effectiveness, the Company hereby acknowledges the following:
· should the Commission or the Staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
· the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If the Staff has any questions or comments concerning this letter, or if you require any additional information, please do not hesitate to contact our counsel, Benjamin M. Roth of Wachtell, Lipton, Rosen & Katz, at (212) 403-1378 or at BMRoth@wlrk.com. We request that we be notified of the effectiveness of the Registration Statement by a telephone call to Mr. Roth and that such effectiveness also be confirmed in writing.
YUM CHINA HOLDINGS, INC.
By:
/s/ Micky Pant
Name:
Micky Pant
Title:
Chief Executive Officer
cc:
Benjamin M. Roth
Wachtell, Lipton, Rosen & Katz
Scott Catlett
Vice President and Deputy General Counsel, Yum! Brands, Inc.
Show Raw Text
CORRESP 1 filename1.htm [LETTERHEAD OF YUM CHINA HOLDINGS, INC.] October 5, 2016 VIA EDGAR Mr. Justin Dobbie Legal Branch Chief Office of Transportation and Leisure U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Yum China Holdings, Inc. Registration Statement on Form S-1 File No. 333-213719 Request for Acceleration Dear Mr. Dobbie: Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Yum China Holdings, Inc. (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form S-1 filed with the U.S. Securities and Exchange Commission (the “Commission”) on October 5, 2016 (File No. 333-213719) (as amended to date, the “Registration Statement”), be accelerated to 10 a.m., Eastern Time, on October 7, 2016, or as soon as practicable thereafter. In connection with the foregoing request for acceleration of effectiveness, the Company hereby acknowledges the following: · should the Commission or the Staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; · the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and · the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. If the Staff has any questions or comments concerning this letter, or if you require any additional information, please do not hesitate to contact our counsel, Benjamin M. Roth of Wachtell, Lipton, Rosen & Katz, at (212) 403-1378 or at BMRoth@wlrk.com. We request that we be notified of the effectiveness of the Registration Statement by a telephone call to Mr. Roth and that such effectiveness also be confirmed in writing. YUM CHINA HOLDINGS, INC. By: /s/ Micky Pant Name: Micky Pant Title: Chief Executive Officer cc: Benjamin M. Roth Wachtell, Lipton, Rosen & Katz Scott Catlett Vice President and Deputy General Counsel, Yum! Brands, Inc. 2