SEC Company Response from Virgin Galactic Holdings, Inc (SPCE) (CIK 0001706946) (SPCE) — Aug 23, 2017
Virgin Galactic Holdings, Inc (SPCE) (CIK 0001706946)
Date: Aug. 23, 2017 · CIK: 0001706946 · Accession: 0001144204-17-044792
AI Filing Summary & Sentiment
Reasoning
Letter
VIA EDGAR Office of Financial Services Division of Corporation Finance RE: Social Capital Hedosophia Holdings Corp. Registration Statement on Form S-1 Filed August 23, 2017 CIK No. 0001706946
Dear Ms. Martin:
On behalf of Social Capital Hedosophia Holdings Corp. (the “Company,” “we,” or “our”), in connection with the proposed initial public offering of the Company’s securities, we have filed today the Company’s Registration Statement on Form S-1 (the “Registration Statement”). The changes reflected in the Registration Statement include those made to reflect the public filing, an increase in the offering size and the filing of certain exhibits as well as other updates.
We advise the staff (“Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange Commission that we are providing to the Staff on a supplemental basis copies of the written communications, as defined in Rule 405 under the Securities Act of 1933, as amended (the “Securities Act”), that were used in meetings with potential investors in reliance on Section 5(d) of the Securities Act. Pursuant to Rule 418 under the Securities Act, such copies shall not be deemed to be filed with, or a part of or included in, the Registration Statement. Additionally, pursuant to Rule 418(b) under the Securities Act, we request that the Staff return or destroy copies of such materials to us. We confirm that no copies of such written communications were retained by potential investors. Other than these materials, we have not presented any written communications to potential investors in reliance on Section 5(d) of the Securities Act, and we have not authorized anyone to do so on our behalf.
* * *
U.S. Securities and Exchange Commission
August 23, 2017
Page 2
Please contact me at (213) 687-5527 should you require further information.
Very truly yours,
/s/ Jonathan Ko
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Skadden,
Arps, Slate, Meagher & Flom llp
DIRECT
DIAL
(213) 687-5527
DIRECT FAX
(213) 621-5527
EMAIL ADDRESS
JONATHAN.KO@SKADDEN.COM
300 South Grand Avenue
Los
Angeles, California 90071-3144
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TEL: (213) 687-5000
FAX: (213) 687-5600
www.skadden.com
August 23, 2017
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VIA EDGAR
Erin E. Martin
Special Counsel
Office of Financial Services
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
RE: Social Capital Hedosophia Holdings Corp.
Registration
Statement on Form S-1
Filed August 23, 2017
CIK
No. 0001706946
Dear Ms. Martin:
On behalf of Social Capital Hedosophia
Holdings Corp. (the “Company,” “we,” or “our”), in connection with the
proposed initial public offering of the Company’s securities, we have filed today the Company’s Registration Statement
on Form S-1 (the “Registration Statement”). The changes reflected in the Registration Statement include those
made to reflect the public filing, an increase in the offering size and the filing of certain exhibits as well as other updates.
We advise the staff (“Staff”)
of the Division of Corporation Finance of the U.S. Securities and Exchange Commission that we are providing to the Staff on a supplemental
basis copies of the written communications, as defined in Rule 405 under the Securities Act of 1933, as amended (the “Securities
Act”), that were used in meetings with potential investors in reliance on Section 5(d) of the Securities Act. Pursuant to
Rule 418 under the Securities Act, such copies shall not be deemed to be filed with, or a part of or included in, the Registration
Statement. Additionally, pursuant to Rule 418(b) under the Securities Act, we request that the Staff return or destroy copies of
such materials to us. We confirm that no copies of such written communications were retained by potential investors. Other than
these materials, we have not presented any written communications to potential investors in reliance on Section 5(d) of the Securities
Act, and we have not authorized anyone to do so on our behalf.
* * *
U.S. Securities and Exchange Commission
August 23, 2017
Page 2
Please contact me at (213) 687-5527 should you
require further information.
Very truly yours,
/s/ Jonathan Ko
Jonathan Ko
cc: Social Capital Hedosophia Holdings Corp.
Chamath Palihapitiya
cc: Shearman & Sterling LLP
Harald Halbhuber, Esq. and Ilir Mujalovic,
Esq.