SEC Company Response from Sea Ltd (SE) (CIK 0001703399) (SE) — Oct 17, 2017
Sea Ltd (SE) (CIK 0001703399)
Date: Oct. 17, 2017 · CIK: 0001703399 · Accession: 0001193125-17-311611
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38237, 333-220571
Letter
UNDERWRITER'S ACCELERATION REQUEST
Goldman Sachs (Asia) L.L.C.
68th Floor, Cheung Kong Center
2 Queen’s Road Central, Hong Kong
Morgan Stanley & Co. International plc
25 Cabot Square
Canary Wharf
London E14 4QA
United Kingdom
Credit Suisse Securities (USA) L.L.C.
Eleven Madison Avenue
New York, NY 10010
United States
VIA EDGAR
October 17, 2017
Mr. Larry Spirgel, Assistant Director
Ms. Celeste M. Murphy, Legal Branch Chief
Mr. Courtney Lindsay, Staff Attorney
Mr. Terry French, Accountant Branch Chief
Mr. Charles Eastman, Staff Accountant
AD Office 11 – Telecommunications
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Sea Limited (CIK: 0001703399)
Registration Statement on Form F-1 (Registration No. 333-220571)
Registration Statement on Form 8-A (Registration No. 001-38237)
Ladies and Gentlemen:
We hereby join Sea Limited (the “Company”) in connection with its request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 4:30 p.m., Eastern Standard Time, on October 19, 2017, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Kirkland & Ellis International LLP, may orally request by telephone call that such Registration Statement be declared effective.
Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated October 6, 2017, through the date hereof:
Preliminary Prospectus dated October 6, 2017:
4131 copies to prospective underwriters, institutional investors, dealers and others.
The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[Signature page follows]
Very truly yours,
GOLDMAN SACHS (ASIA) L.L.C.
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CORRESP 1 filename1.htm UNDERWRITER'S ACCELERATION REQUEST Goldman Sachs (Asia) L.L.C. 68th Floor, Cheung Kong Center 2 Queen’s Road Central, Hong Kong Morgan Stanley & Co. International plc 25 Cabot Square Canary Wharf London E14 4QA United Kingdom Credit Suisse Securities (USA) L.L.C. Eleven Madison Avenue New York, NY 10010 United States VIA EDGAR October 17, 2017 Mr. Larry Spirgel, Assistant Director Ms. Celeste M. Murphy, Legal Branch Chief Mr. Courtney Lindsay, Staff Attorney Mr. Terry French, Accountant Branch Chief Mr. Charles Eastman, Staff Accountant AD Office 11 – Telecommunications Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Sea Limited (CIK: 0001703399) Registration Statement on Form F-1 (Registration No. 333-220571) Registration Statement on Form 8-A (Registration No. 001-38237) Ladies and Gentlemen: We hereby join Sea Limited (the “Company”) in connection with its request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 4:30 p.m., Eastern Standard Time, on October 19, 2017, or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Kirkland & Ellis International LLP, may orally request by telephone call that such Registration Statement be declared effective. Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended, we wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated October 6, 2017, through the date hereof: Preliminary Prospectus dated October 6, 2017: 4131 copies to prospective underwriters, institutional investors, dealers and others. The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [Signature page follows] Very truly yours, GOLDMAN SACHS (ASIA) L.L.C. MORGAN STANLEY & CO. INTERNATIONAL PLC CREDIT SUISSE SECURITIES (USA) L.L.C. As Representatives of the several Underwriters By: GOLDMAN SACHS (ASIA) L.L.C. By: /s/ Iain Drayton Name: Iain Drayton Title: Managing Director By: MORGAN STANLEY & CO. INTERNATIONAL PLC By: /s/ Peter Chu Name: Peter Chu Title: Managing Director By: CREDIT SUISSE SECURITIES (USA) L.L.C. By: /s/ Marc Bernstein Name: Marc Bernstein Title: Director [Acceleration Request]