SEC Company Response from J & Friends Holdings Ltd (JF) (CIK 0001716338) (JF) — Jul 16, 2018
J & Friends Holdings Ltd (JF) (CIK 0001716338)
Date: July 16, 2018 · CIK: 0001716338 · Accession: 0001104659-18-045277
AI Filing Summary & Sentiment
Reasoning
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Pintec Technology Holdings Limited Registration Statement on Form F-1 CIK No. 0001716338
Dear Ms. Woo, Mr. Edgar, Ms. Dietz, Mr. Nolan and Ms. Jacobs:
On behalf of our client, Pintec Technology Holdings Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits via EDGAR with the Securities and Exchange Commission (the “Commission”).
To facilitate your review, we have separately delivered to you today five courtesy copies of the Registration Statement, marked to show changes to the revised draft registration statement confidentially submitted on June 19, 2018. However, please note that we have left the entire section entitled “Description of American Depositary Shares” unmarked for ease of reading, even though the entire section has been replaced with a different draft since the revised draft registration statement confidentially submitted on June 19, 2018.
In accordance with the Jumpstart Our Business Startups Act, as amended, the Company plans to file an amendment to the Registration Statement containing the
estimated price range and offering size and launch the road show no earlier than 15 days after the date hereof.
If you have any questions regarding the Registration Statement, please contact the undersigned by phone at +852 3740-4863 or by e-mail at julie.gao@skadden.com, or Geoffrey Wang, the audit engagement partner at PricewaterhouseCoopers Zhong Tian LLP, by telephone at +86 10-6533-2928 or by email at geoffrey.wang@cn.pwc.com. PricewaterhouseCoopers Zhong Tian LLP is the independent registered public accounting firm of the Company.
Very truly yours,
/s/ Z. Julie Gao
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CORRESP 1 filename1.htm SKADDEN, ARPS, SLATE, MEAGHER & FLOM PARTNERS 世達國際律師事務所 AFFILIATE OFFICES CHRISTOPHER W. BETTS 42/F, EDINBURGH TOWER, THE LANDMARK WILL H. CAI ^ 15 QUEEN’S ROAD CENTRAL, HONG KONG BOSTON GEOFFREY CHAN * CHICAGO ANDREW L. FOSTER * TEL: (852) 3740-4700 HOUSTON CHI T. STEVE KWOK * FAX: (852) 3740-4727 LOS ANGELES EDWARD H.P. LAM ¨* www.skadden.com NEW YORK HAIPING LI * PALO ALTO RORY MCALPINE ¨ WASHINGTON, D.C. CLIVE W. ROUGH ¨ WILMINGTON JONATHAN B. STONE * BEIJING ^ (ALSO ADMITTED IN CALIFORNIA) BRUSSELS ¨ (ALSO ADMITTED IN ENGLAND & WALES) FRANKFURT * (ALSO ADMITTED IN NEW YORK) LONDON MOSCOW REGISTERED FOREIGN LAWYERS MUNICH Z. JULIE GAO (CALIFORNIA) PARIS BRADLEY A. KLEIN (ILLINOIS) SÃO PAULO SEOUL SHANGHAI SINGAPORE July 16, 2018 TOKYO TORONTO VIA EDGAR Jan Woo, Legal Branch Chief David Edgar, Staff Accountant Christine Dietz, Assistant Chief Accountant Bernard Nolan, Attorney-Adviser Barbara C. Jacobs, Assistant Director Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Pintec Technology Holdings Limited Registration Statement on Form F-1 CIK No. 0001716338 Dear Ms. Woo, Mr. Edgar, Ms. Dietz, Mr. Nolan and Ms. Jacobs: On behalf of our client, Pintec Technology Holdings Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits via EDGAR with the Securities and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you today five courtesy copies of the Registration Statement, marked to show changes to the revised draft registration statement confidentially submitted on June 19, 2018. However, please note that we have left the entire section entitled “Description of American Depositary Shares” unmarked for ease of reading, even though the entire section has been replaced with a different draft since the revised draft registration statement confidentially submitted on June 19, 2018. In accordance with the Jumpstart Our Business Startups Act, as amended, the Company plans to file an amendment to the Registration Statement containing the estimated price range and offering size and launch the road show no earlier than 15 days after the date hereof. If you have any questions regarding the Registration Statement, please contact the undersigned by phone at +852 3740-4863 or by e-mail at julie.gao@skadden.com, or Geoffrey Wang, the audit engagement partner at PricewaterhouseCoopers Zhong Tian LLP, by telephone at +86 10-6533-2928 or by email at geoffrey.wang@cn.pwc.com. PricewaterhouseCoopers Zhong Tian LLP is the independent registered public accounting firm of the Company. Very truly yours, /s/ Z. Julie Gao Z. Julie Gao Enclosures cc: Wei Wei, Chief Executive Officer, Pintec Technology Holdings Limited Steven Yuan Ning Sim, Chief Financial Officer, Pintec Technology Holdings Limited Geoffrey Wang, Partner, PricewaterhouseCoopers Zhong Tian LLP Chris K.H. Lin, Esq., Simpson Thacher & Bartlett LLP 2