SEC Company Response from 111, Inc. (YI) (CIK 0001738906) (YI) — Sep 7, 2018
111, Inc. (YI) (CIK 0001738906)
Date: Sept. 7, 2018 · CIK: 0001738906 · Accession: 0001104659-18-055740
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-38639, 333-226849
Letter
J.P. Morgan Securities LLC
383 Madison Avenue
New York, New York 10179
Citigroup Global Markets Inc.
388 Greenwich Street
New York, New York 10013
China International Capital Corporation Hong Kong Securities Limited
29th Floor, One International Finance Centre
1 Harbour View Street, Central
Hong Kong
September 7, 2018
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010
Attn: John Reynolds / Brigitte Lippman / Jonathan Burr / Blaise Rhodes / Raj Rajan
Re:111, Inc.
Registration Statement on Form F-1, as amended (File No. 333-226849)
Registration Statement on Form 8-A (File No. 001-38639)
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of 111, Inc. (the “Company”) for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 5:00 PM, Eastern Time, on September 11, 2018 or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Skadden, Arps, Slate, Meagher & Flom LLP, may orally request by telephone call that such Registration Statement be declared effective.
Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated August 29, 2018:
(i) Dates of distribution: August 30, 2018 through the date hereof
(ii) Number of prospective underwriters to which the preliminary prospectus was furnished: 3
(iii) Number of prospectuses furnished to investors: approximately 2000
(iv) Number of prospectuses distributed to others, including the Company, the Company’s counsel, independent accountants, and underwriters’ counsel: approximately 100
We, the undersigned, as representatives of the several underwriters, have complied and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
Very truly yours,
J.P. MORGAN SECURITIES LLC
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CORRESP 1 filename1.htm J.P. Morgan Securities LLC 383 Madison Avenue New York, New York 10179 Citigroup Global Markets Inc. 388 Greenwich Street New York, New York 10013 China International Capital Corporation Hong Kong Securities Limited 29th Floor, One International Finance Centre 1 Harbour View Street, Central Hong Kong September 7, 2018 Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-7010 Attn: John Reynolds / Brigitte Lippman / Jonathan Burr / Blaise Rhodes / Raj Rajan Re:111, Inc. Registration Statement on Form F-1, as amended (File No. 333-226849) Registration Statement on Form 8-A (File No. 001-38639) Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), we, as representatives of the several underwriters, hereby join in the request of 111, Inc. (the “Company”) for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 5:00 PM, Eastern Time, on September 11, 2018 or as soon thereafter as practicable, or at such other time as the Company or its outside counsel, Skadden, Arps, Slate, Meagher & Flom LLP, may orally request by telephone call that such Registration Statement be declared effective. Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that we have effected the following distribution of the Company’s Preliminary Prospectus dated August 29, 2018: (i) Dates of distribution: August 30, 2018 through the date hereof (ii) Number of prospective underwriters to which the preliminary prospectus was furnished: 3 (iii) Number of prospectuses furnished to investors: approximately 2000 (iv) Number of prospectuses distributed to others, including the Company, the Company’s counsel, independent accountants, and underwriters’ counsel: approximately 100 We, the undersigned, as representatives of the several underwriters, have complied and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. Very truly yours, J.P. MORGAN SECURITIES LLC CITIGROUP GLOBAL MARKETS INC. CHINA INTERNATIONAL CAPITAL CORPORATION HONG KONG SECURITIES LIMITED By: J.P. MORGAN SECURITIES LLC By: /s/ Brian Dunlap Name: Brian Dunlap Title: Vice President By: CITIGROUP GLOBAL MARKETS INC. By: /s/ James Perry Name: James Perry Title: Managing Director By: CHINA INTERNATIONAL CAPITAL CORPORATION HONG KONG SECURITIES LIMITED By: /s/ Shuguang Wang. Name: Shuguang Wang. Title: Managing Director