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CORRESP Filing

111, Inc.
Date: Aug. 22, 2025 · CIK: 0001738906 · Accession: 0000950103-25-010592

Financial Reporting Regulatory Compliance Internal Controls

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File numbers found in text: 001-38639

Referenced dates: August 11, 2025

Date
August 22, 2025
Author
By
Form
CORRESP
Company
111, Inc.

Letter

Division of Corporation Finance U.S. Securities & Exchange Commission 100 F Street, NE Washington, D.C. 20549 111, Inc. Annual Report on Form 20-F Filed April 29, 2025 File No. 001-38639 Attn: Division of Corporation Finance Office of Trade & Services VIA EDGAR

Re:

Dear Blaise Rhodes and Rufus Decker:

111, Inc. (the " Company ") acknowledges receipt of a comment letter from the staff (the " Staff ") of the Securities and Exchange Commission dated August 11, 2025 (the " Comment Letter ") with respect to the Company's Form 20-F for the fiscal year ended December 31, 2024 and response dated August 6, 2025.

The Company has carefully reviewed and considered the Staff's comments and is in the process of preparing responses to these comments. The Company respectfully advises the Staff that since it needs additional time to prepare thorough and sufficient responses to the Comment Letter, the Company respectfully requests an extension of the deadline for its responses. The Company expects to provide its responses to the Comment Letter by August 29, 2025.

If you have further questions or comments regarding, or require further information or clarification of, any of the responses provided in this letter or if the Commission has any questions with respect to 111, Inc.'s Annual Report on Form 20-F, please contact the undersigned or Kevin Zhang (Tel: +852-2533-3384) of Davis Polk & Wardwell LLP.

Sincerely yours,
111, Inc.

Show Raw Text
CORRESP
 1
 filename1.htm

 August 22, 2025

 Division of Corporation Finance
U.S. Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549

 Re:

 111, Inc.
 Annual Report on Form 20-F

 Filed April 29, 2025
 File No. 001-38639

 Attn:
 Division of Corporation Finance
Office of Trade & Services

 VIA EDGAR

 Dear Blaise Rhodes and Rufus Decker:

 111, Inc. (the " Company ") acknowledges
receipt of a comment letter from the staff (the " Staff ") of the Securities and Exchange Commission dated August 11,
2025 (the " Comment Letter ") with respect to the Company's Form 20-F for the fiscal year ended December 31,
2024 and response dated August 6, 2025.

 The Company has carefully reviewed and considered
the Staff's comments and is in the process of preparing responses to these comments. The Company respectfully advises the Staff
that since it needs additional time to prepare thorough and sufficient responses to the Comment Letter, the Company respectfully requests
an extension of the deadline for its responses. The Company expects to provide its responses to the Comment Letter by August 29, 2025.

 If you have further questions or comments regarding,
or require further information or clarification of, any of the responses provided in this letter or if the Commission has any questions
with respect to 111, Inc.'s Annual Report on Form 20-F, please contact the undersigned or Kevin Zhang (Tel: +852-2533-3384) of Davis
Polk & Wardwell LLP.

 Sincerely yours,

 111, Inc.

 By:

 /s/ Junling
Liu

 Name: Junling Liu

 Title: Chief Executive Officer

 cc:
 Kevin Zhang

 Davis Polk & Wardwell LLP