SEC Company Response from 111, Inc. (YI) (CIK 0001738906) (YI) — Aug 29, 2018
111, Inc. (YI) (CIK 0001738906)
Date: Aug. 29, 2018 · CIK: 0001738906 · Accession: 0001104659-18-054120
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-226849
Letter
VIA EDGAR Division of Corporation Finance Securities and Exchange Commission U. S. A. Re: 111, Inc. (CIK No.0001738906) Registration Statement on Form F-1 (File No. 333-226849)
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 Amendment No. 1 to the 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 registration statement on Form F-1 filed on August 15, 2018, as well as two copies of the filed exhibits.
The Company will commence marketing activities in connection with the offering shortly after the date hereof. The Company plans to request that the Staff declare the effectiveness of the Registration Statement on or about September 11, 2018, and will file the joint acceleration requests in time before the requested effective time. 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.
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 WILL H. CAI ^ 42/F, EDINBURGH TOWER, THE LANDMARK BOSTON GEOFFREY CHAN * 15 QUEEN’S ROAD CENTRAL, HONG KONG CHICAGO ANDREW L. FOSTER * HOUSTON CHI T. STEVE KWOK * TEL: (852) 3740-4700 LOS ANGELES EDWARD H.P. LAM ¨* FAX: (852) 3740-4727 NEW YORK HAIPING LI * www.skadden.com 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 29, 2018 VIA 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 (File No. 333-226849) 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 Amendment No. 1 to the 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 registration statement on Form F-1 filed on August 15, 2018, as well as two copies of the filed exhibits. The Company will commence marketing activities in connection with the offering shortly after the date hereof. The Company plans to request that the Staff declare the effectiveness of the Registration Statement on or about September 11, 2018, and will file the joint acceleration requests in time before the requested effective time. The Company would appreciate the Staff’s timely assistance and support to the Company in meeting the proposed timetable for the offering. * * * 2 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. 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 3