SEC Company Response from NaaS Technology Inc. (NAAS) (CIK 0001712178) (NAAS) — Oct 17, 2017
NaaS Technology Inc. (NAAS) (CIK 0001712178)
Date: Oct. 17, 2017 · CIK: 0001712178 · Accession: 0001193125-17-311656
AI Filing Summary & Sentiment
File numbers found in text: 001-38235, 333-220587
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CORRESP
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filename1.htm
Company Acceleration Request
RISE Education Cayman Ltd
Room 101, Jia He Guo Xin Mansion
No.15 Baiqiao Street, Guangqumennei, Dongcheng District
Beijing 100062, People’s Republic of China
October 17, 2017
VIA EDGAR CORRESPONDENCE AND
FACSIMILE
Mr. Larry Spirgel, Assistant Director
Ms. Kathleen Krebs, Special Counsel
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:
RISE Education Cayman Ltd (CIK: 0001712178)
Registration Statement on Form F-1 (File No. 333-220587)
Registration Statement on Form 8-A (File No. 001-38235)
Ladies and Gentlemen:
In accordance with Rule 461 of Regulation C (“Rule 461”) of the General Rules and Regulations under the Securities Act of 1933, as
amended, RISE Education Cayman Ltd (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1 (the
“F-1 Registration Statement”) be accelerated to and that the F-1 Registration Statement become effective at 4:00 p.m., Eastern Time, on October 19, 2017,
or as soon thereafter as practicable.
The Company also requests that the Registration Statement on Form
8-A under the Securities Exchange Act of 1934, as amended, covering the American depositary shares representing Class A ordinary shares of the Company, be declared effective concurrently with the F-1 Registration Statement (the F-1 Registration Statement, together with the Registration Statement on Form 8-A, the
“Registration Statements”).
If there is any change in the acceleration request set forth above, the Company will promptly
notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. The request may be made by an executive officer of the Company or by
any attorney from the Company’s U.S. counsel, Kirkland & Ellis International LLP.
The Company understands that Morgan
Stanley & Co. International plc, Credit Suisse Securities (USA) L.L.C. and UBS Securities LLC, the representatives of the underwriters of the offering, have joined in this request in a separate letter filed with the Securities and Exchange
Commission today.
[Signature page follows]
Very truly yours,
RISE Education Cayman Ltd
By:
/s/ Yiding Sun
Name:
Yiding Sun
Title:
Director and Chief Executive Officer