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SEC Company Response from Niu Technologies (NIU) — Oct 9, 2018

Niu Technologies
Date: Oct. 9, 2018 · CIK: 0001744781 · Accession: 0001104659-18-061009

AI Filing Summary & Sentiment

File numbers found in text: 333-227497

Date
Oct. 9, 2018
Author
/s/ Z. Julie Gao
Form
CORRESP
Company
Niu Technologies

Letter

VIA EDGAR Division of Corporation Finance Washington, D.C. 20549 Re: Niu Technologies (CIK No. 0001744781) Registration Statement on Form F-1 (File No. 333-227497)

Dear Mr. McWilliams, Ms. Griffith, Mr. Shenk and Ms. Gilmore:

On behalf of our client, Niu Technologies, a company 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 with the Securities and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you four courtesy copies of the Registration Statement, marked to show changes to the registration statement filed with the Commission on September 24, 2018.

The Company will commence the 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 October 18, 2018, and will file the joint acceleration requests in time before the requested effective time. The Company would greatly appreciate the Staff’s continued assistance and support in meeting its timetable.

* * *

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

Show Raw Text
CORRESP
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filename1.htm

SKADDEN, ARPS, SLATE, MEAGHER & FLOM

世達國際律師事務所

AFFILIATE OFFICES

PARTNERS

42/F, EDINBURGH TOWER, THE LANDMARK

CHRISTOPHER W. BETTS

15 QUEEN’S ROAD CENTRAL, HONG KONG

BOSTON

WILL H. CAI ^

CHICAGO

GEOFFREY CHAN *

TEL: (852) 3740-4700

HOUSTON

ANDREW L. FOSTER *

FAX: (852) 3740-4727

LOS ANGELES

BRADLEY A. KLEIN ˜

www.skadden.com

NEW YORK

CHI T. STEVE KWOK *

PALO ALTO

EDWARD H.P. LAM ¨*

WASHINGTON, D.C.

HAIPING LI *

WILMINGTON

RORY MCALPINE ¨

CLIVE W. ROUGH ¨

BEIJING

JONATHAN B. STONE *

BRUSSELS

FRANKFURT

LONDON

^ (ALSO ADMITTED IN CALIFORNIA)

MOSCOW

¨ (ALSO ADMITTED IN ENGLAND & WALES)

MUNICH

˜ (ALSO ADMITTED IN ILLINOIS)

PARIS

* (ALSO ADMITTED IN NEW YORK)

SÃO PAULO

SEOUL

REGISTERED FOREIGN LAWYER

SHANGHAI

Z. JULIE GAO (CALIFORNIA)

SINGAPORE

TOKYO

October 9, 2018

TORONTO

VIA EDGAR

Mr. J. Nolan McWilliams

Ms. Julie Griffith

Mr. Lyn Shenk

Ms. Melissa Gilmore

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C.  20549

Re:

Niu   Technologies (CIK No. 0001744781)

Registration Statement on   Form F-1 (File No. 333-227497)

Dear Mr. McWilliams, Ms. Griffith, Mr. Shenk and Ms. Gilmore:

On behalf of our client, Niu Technologies, a company 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 with the Securities and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you four courtesy copies of the Registration Statement, marked to show changes to the registration statement filed with the Commission on September 24, 2018.

The Company will commence the 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 October 18, 2018, and will file the joint acceleration requests in time before the requested effective time. The Company would greatly appreciate the Staff’s continued assistance and support in meeting its timetable.

*              *              *

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

Enclosures

cc:

Yan Li, Chairman and   Chief Executive Officer, Niu Technologies

Hardy Peng Zhang,   Chief Financial Officer, Niu Technologies

Allen Lu, Partner,   KPMG Huazhen LLP

David Zhang, Partner,   Kirkland & Ellis International LLP

Steve Lin, Partner, Kirkland &   Ellis International LLP

2