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SEC Company Response from HUYA Inc. (HUYA) (CIK 0001728190) (HUYA) — May 10, 2018

HUYA Inc. (HUYA) (CIK 0001728190)
Date: May 10, 2018 · CIK: 0001728190 · Accession: 0001193125-18-158966

AI Filing Summary & Sentiment

File numbers found in text: 333-224202

Referenced dates: May 9, 2018

Date
May 10, 2018
Author
/s/ Z. Julie Gao
Form
CORRESP
Company
HUYA Inc. (HUYA) (CIK 0001728190)

Letter

VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549 Re: HUYA, Inc. (CIK No. 0001728190) Amendment No. 4 to Registration Statement on Form F-1 (File No. 333-224202) Response to the Staff’s Comment Dated May 9, 2018

Dear Ms. Jacobs, Ms. Ayoola, Mr. Wilson and Ms. Walsh:

On behalf of our client, HUYA, Inc., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s Amended No. 4 to the Registration Statement on Form F-1 (the “Registration Statement”) via EDGAR with the Securities and Exchange Commission (the “Commission”).

Securities and Exchange Commission

May 10, 2018

Page

In consideration of oral comment from the staff of the Commission (the “Staff”) on May 9, 2018, the Company hereby supplements its response to the Staff’s comment No. 4 in the response letter dated May 9, 2018. In Amendment No. 4 to the Registration Statement filed herewith, the Company has revised the statement on waiver of jury trial in relation to federal securities law claims that was previously added on page 179 in the last filing.

Securities and Exchange Commission

May 10, 2018

Page

* * *

If you have any questions regarding the Amendment No. 4, please contact the undersigned by phone at +852-3740-4863 or via e-mail at julie.gao@skadden.com.

Very truly yours,
/s/ Z. Julie Gao

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 SKADDEN, ARPS, SLATE, MEAGHER & FLOM

 世 達 國 際 律 師
事 務 所

 PARTNERS

CHRISTOPHER W. BETTS

WILL H. CAI ^

GEOFFREY CHAN *

CHI T. STEVE KWOK *

EDWARD H.P. LAM ◆*

HAIPING LI *

 RORY
MCALPINE ◆

 CLIVE W. ROUGH ◆

JONATHAN B. STONE *

 ^
(ALSO ADMITTED IN CALIFORNIA)

 ◆ (ALSO ADMITTED
IN ENGLAND & WALES)

 * (ALSO ADMITTED IN
NEW YORK)

 REGISTERED
FOREIGN LAWYERS

 ANDREW L. FOSTER (NEW YORK)

Z. JULIE GAO (CALIFORNIA)

BRADLEY A. KLEIN (ILLINOIS)

 42/F, EDINBURGH TOWER, THE LANDMARK

15 QUEEN’S ROAD CENTRAL, HONG KONG

 TEL: (852) 3740-4700

FAX: (852) 3740-4727

www.skadden.com

 AFFILIATE OFFICES

 BOSTON

CHICAGO

 HOUSTON

LOS ANGELES

 NEW YORK

PALO ALTO

 WASHINGTON, D.C.

WILMINGTON

 BEIJING

BRUSSELS

 FRANKFURT

LONDON

 MOSCOW

MUNICH

 PARIS

SÃO PAULO

 SEOUL

SHANGHAI

 SINGAPORE

TOKYO

 TORONTO

 May 10, 2018

VIA EDGAR

 Ms. Barbara C. Jacobs

Ms. Folake Ayoola

 Mr. Craig Wilson

Ms. Melissa Walsh

 Division of Corporation Finance

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
HUYA, Inc. (CIK No. 0001728190)

 Amendment No. 4 to
Registration Statement on Form F-1 (File No. 333-224202)

Response to the Staff’s Comment Dated May 9, 2018

Dear Ms. Jacobs, Ms. Ayoola, Mr. Wilson and Ms. Walsh:

On behalf of our client, HUYA, Inc., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”),
we are filing herewith the Company’s Amended No. 4 to the Registration Statement on Form F-1 (the “Registration Statement”) via EDGAR with the Securities and Exchange Commission (the
“Commission”).

 Securities and Exchange Commission

May 10, 2018

  Page
 2

 In consideration of oral comment from the staff of the Commission (the
“Staff”) on May 9, 2018, the Company hereby supplements its response to the Staff’s comment No. 4 in the response letter dated May 9, 2018. In Amendment No. 4 to the Registration Statement filed herewith,
the Company has revised the statement on waiver of jury trial in relation to federal securities law claims that was previously added on page 179 in the last filing.

 Securities and Exchange Commission

May 10, 2018

  Page
 3

*        *        *

If you have any questions regarding the Amendment No. 4, please contact the undersigned by phone at
+852-3740-4863 or via e-mail at julie.gao@skadden.com.

Very truly yours,

 /s/ Z. Julie Gao

Z. Julie Gao

 Enclosures

cc:
Rongjie Dong, Chief Executive Officer and Director, HUYA Inc.

 Dachuan Sha, Chief Financial
Officer, HUYA Inc.

 Haiping Li, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP

Alex Chan, Audit Partner, PricewaterhouseCoopers Zhong Tian LLP

David Zhang, Esq., Partner, Kirkland & Ellis International LLP

Steve Lin, Esq., Partner, Kirkland & Ellis International LLP