SEC Company Response from 111, Inc. (YI) (CIK 0001738906) (YI) — Aug 15, 2018
111, Inc. (YI) (CIK 0001738906)
Date: Aug. 15, 2018 · CIK: 0001738906 · Accession: 0001104659-18-052234
AI Filing Summary & Sentiment
Reasoning
Letter
Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 U. S. A. Re: 111, Inc. (CIK No.0001738906) Registration Statement on Form F-1
Dear Mr. Reynolds, Ms. Lippman, Mr. Burr, Mr. Rhodes and Mr. Rajan:
On behalf of our client, 111, Inc., 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 to the Securities and Exchange Commission (the “Commission”).
To facilitate the review by the staff of the Commission (the “Staff”), we have separately delivered to the Staff today five courtesy copies of the Registration Statement, marked to show changes to the draft registration statement on Form F-1 confidentially submitted to the Commission on July 27, 2018 pursuant to the Jumpstart Our Business Startups Act, as amended, as well as two copies of the filed exhibits.
The Company respectfully advises the Staff that it plans to file an amendment to the Registration Statement containing the estimated offering size and price range on or about August 29, 2018, and commence the road show for the proposed offering immediately thereafter. The Company would appreciate the Staff’s timely assistance and support to the Company in meeting the proposed timetable for the offering.
* * *
If you have any questions regarding the Registration Statement, please contact the undersigned by phone at +852-3740-4863 or via e-mail at julie.gao@skadden.com or Jimmy Chen, the audit engagement partner at Deloitte Touche Tohmatsu Certified Public Accountants LLP, by telephone at +86 21 6142 2172 or via email at jimmycchen@deloitte.com.cn. Deloitte Touche Tohmatsu Certified Public Accountants LLP is the independent registered public accounting firm of the Company.
Very truly yours,
/s/ Z. Julie Gao
Show Raw Text
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 TOKYO TORONTO August 15, 2018 VIE EDGAR Mr. John Reynolds Ms. Brigitte Lippman Mr. Jonathan Burr Mr. Blaise Rhodes Mr. Raj Rajan Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 U. S. A. Re: 111, Inc. (CIK No.0001738906) Registration Statement on Form F-1 Dear Mr. Reynolds, Ms. Lippman, Mr. Burr, Mr. Rhodes and Mr. Rajan: On behalf of our client, 111, Inc., 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 to the Securities and Exchange Commission (the “Commission”). To facilitate the review by the staff of the Commission (the “Staff”), we have separately delivered to the Staff today five courtesy copies of the Registration Statement, marked to show changes to the draft registration statement on Form F-1 confidentially submitted to the Commission on July 27, 2018 pursuant to the Jumpstart Our Business Startups Act, as amended, as well as two copies of the filed exhibits. The Company respectfully advises the Staff that it plans to file an amendment to the Registration Statement containing the estimated offering size and price range on or about August 29, 2018, and commence the road show for the proposed offering immediately thereafter. The Company would appreciate the Staff’s timely assistance and support to the Company in meeting the proposed timetable for the offering. * * * If you have any questions regarding the Registration Statement, please contact the undersigned by phone at +852-3740-4863 or via e-mail at julie.gao@skadden.com or Jimmy Chen, the audit engagement partner at Deloitte Touche Tohmatsu Certified Public Accountants LLP, by telephone at +86 21 6142 2172 or via email at jimmycchen@deloitte.com.cn. Deloitte Touche Tohmatsu Certified Public Accountants LLP is the independent registered public accounting firm of the Company. Very truly yours, /s/ Z. Julie Gao Z. Julie Gao cc: Gang Yu, Executive Chairman, 111, Inc. Junling Liu, Chairman and Chief Executive Officer, 111, Inc. Weihao Xu, Chief Financial Officer, 111, Inc. Haiping Li, Partner, Skadden, Arps, Slate, Meagher & Flom LLP Jimmy Chen, Partner, Deloitte Touche Tohmatsu Certified Public Accountants LLP Yan Chen, Partner, Freshfields Bruckhaus Deringer LLP Valerie Ford Jacob, Partner, Freshfields Bruckhaus Deringer LLP 2