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SEC Company Response from Cango Inc. (CANG) (CIK 0001725123) (CANG) — Jul 16, 2018

Cango Inc. (CANG) (CIK 0001725123)
Date: July 16, 2018 · CIK: 0001725123 · Accession: 0001193125-18-218707

Offering / Registration Process Financial Reporting Business Model Clarity

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File numbers found in text: 333-225813

Date
July 16, 2018
Author
/s/ Chris K.H. Lin
Form
CORRESP
Company
Cango Inc. (CANG) (CIK 0001725123)

Letter

CORRESPONDENCE

Simpson Thacher & Bartlett

ICBC TOWER, 35TH FLOOR

3 GARDEN ROAD

HONG KONG

TELEPHONE: +852-2514-7600

FACSIMILE: +852-2869-7694

Direct Dial Number

(852) 2514-7650

E-mail Address

clin@stblaw.com

July 16, 2018

VIA EDGAR

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Mail Stop 4561

Washington, D.C. 20549

Attention: Ms. Katherine Wray, Esq., Attorney-Advisor

Mr. Jeff Kauten, Esq., Attorney-Advisor

Mr. Craig Wilson, Senior Assistant Chief Accountant

Mr. Ryan Rohn, Staff Accountant

Re: Cango Inc.

Registration Statement on Form F-1

File No. 333-225813

Ladies and Gentlemen:

On behalf of our client, Cango Inc., an exempted company incorporated under the laws of the Cayman Islands with limited liability (the “Company”), we are filing herewith Amendment No. 2 (“Amendment No. 2”) to the Company’s above-referenced Registration Statement on Form F-1 (the “Registration Statement”) via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”). The Company notes that it has included the estimated range of the offering price for its initial public offering and related disclosure in the preliminary prospectus which forms a part of Amendment No. 2.

We enclose herewith five (5) courtesy copies of Amendment No. 2, which has been marked to show changes to the Company’s Registration Statement filed with the Commission on July 9, 2018.

Simpson Thacher & Bartlett

July 16, 2018

The Company will commence its road show activities on July 17, 2018 and expects to price the initial public offering on or about July 25, 2018. We would greatly appreciate the Staff’s willingness to work with the Company to achieve this offering timetable.

* * * * *

-2-

Simpson Thacher & Bartlett

July 16, 2018

If you have any question regarding the Registration Statement, please do not hesitate to contact me at +852-2514-7650 (work), +852-9198-4235 (mobile) or clin@stblaw.com (email) or David Lee at +852-2514-7655 (work), +852-9036-9375 (mobile) or dlee@stblaw.com (email).

Questions pertaining to accounting and auditing matters may also be directed to Ron Yan at +86-21-2228-2332 (work) or ron.yan@cn.ey.com (email) of Ernst & Young Hua Ming LLP, the independent registered public accounting firm of the Company.

Very truly yours,
/s/ Chris K.H. Lin

Show Raw Text
CORRESP
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filename1.htm

CORRESPONDENCE

 Simpson Thacher & Bartlett

 ICBC TOWER, 35TH FLOOR

 3 GARDEN ROAD

HONG KONG

TELEPHONE: +852-2514-7600

FACSIMILE: +852-2869-7694

 Direct Dial Number

 (852) 2514-7650

 E-mail Address

clin@stblaw.com

 July 16, 2018

VIA EDGAR

 Division of Corporation Finance

U.S. Securities and Exchange Commission

 100 F Street, N.E.

Mail Stop 4561

 Washington, D.C. 20549

Attention:
Ms. Katherine Wray, Esq., Attorney-Advisor

Mr. Jeff Kauten, Esq., Attorney-Advisor

Mr. Craig Wilson, Senior Assistant Chief Accountant

Mr. Ryan Rohn, Staff Accountant

Re:
Cango Inc.

Registration Statement on Form F-1

File No. 333-225813

 Ladies and Gentlemen:

On behalf of our client, Cango Inc., an exempted company incorporated under the laws of the Cayman Islands with limited liability (the
“Company”), we are filing herewith Amendment No. 2 (“Amendment No. 2”) to the Company’s above-referenced Registration Statement on Form F-1 (the “Registration
Statement”) via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended (the “Securities Act”). The Company notes that it has included the estimated range of the
offering price for its initial public offering and related disclosure in the preliminary prospectus which forms a part of Amendment No. 2.

We enclose herewith five (5) courtesy copies of Amendment No. 2, which has been marked to show changes to the Company’s
Registration Statement filed with the Commission on July 9, 2018.

 Simpson Thacher & Bartlett

 July 16, 2018

 The Company will commence its road show activities on July 17, 2018 and expects to price
the initial public offering on or about July 25, 2018. We would greatly appreciate the Staff’s willingness to work with the Company to achieve this offering timetable.

*    *    *    *    *

 -2-

 Simpson Thacher & Bartlett

 July 16, 2018

 If you have any question regarding the Registration Statement, please do not hesitate to
contact me at +852-2514-7650 (work), +852-9198-4235 (mobile) or clin@stblaw.com (email) or David Lee at +852-2514-7655 (work), +852-9036-9375 (mobile) or dlee@stblaw.com (email).

 Questions pertaining to accounting and auditing
matters may also be directed to Ron Yan at +86-21-2228-2332 (work) or ron.yan@cn.ey.com (email) of Ernst & Young Hua Ming LLP, the independent registered public
accounting firm of the Company.

Very truly yours,

/s/ Chris K.H. Lin

Chris K.H. Lin

 Enclosures

cc:
Xiaojun Zhang, Chairman

 Jiayuan Lin, Chief Executive Officer and Director

Yongyi Zhang, Chief Financial Officer and Director

Cango Inc.

 Daniel Fertig

David Lee

 Simpson
Thacher & Bartlett

 Li He

James C. Lin

 Davis
Polk & Wardwell

 Ron Yan

Ernst & Young Hua Ming LLP

 -3-