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SEC Company Response from Yunji (YJ) — Apr 22, 2019

Yunji Inc.
Date: April 22, 2019 · CIK: 0001759614 · Accession: 0001193125-19-113448

AI Filing Summary & Sentiment

Date
April 22, 2019
Author
/s/ Z. Julie Gao
Form
CORRESP
Company
Yunji Inc.

Letter

VIA EDGAR Division of Corporation Finance Office of Consumer Products Washington, D.C., 20549 Re: Yunji Inc. Registration Statement on Form F-1 CIK No. 0001759614

Dear Ms. Ransom, Ms. López-Molina, Ms. Thompson and Ms. Moosariparambil:

On behalf of our client, Yunji Inc., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s Amendment No. 2 to the registration statement on Form F-1 (the “Registration Statement”) containing the preliminary prospectus with the price range and certain recent developments 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 April 10, 2019.

Securities and Exchange Commission

April 22, 2019

Page

The Company respectfully advises the Commission that the Company plans to commence the road show for the proposed offering on or about April 23, 2019. In addition, the Company plans to request that the Staff declare the effectiveness of the Registration Statement as on or about on May 2, 2019, 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.

* * *

Securities and Exchange Commission

April 22, 2019

Page

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
1
filename1.htm

CORRESP

 SKADDEN, ARPS, SLATE,
MEAGHER & FLOM

 世達國際律師事務所

 PARTNERS

CHRISTOPHER W. BETTS

GEOFFREY CHAN *

ANDREW L. FOSTER *

BRADLEY A. KLEIN ~

CHI T. STEVE KWOK *

EDWARD H.P. LAM ◆*

HAIPING LI *

 RORY
MCALPINE ◆

 JONATHAN B. STONE *

PALOMA P. WANG

 ◆
(ALSO ADMITTED IN ENGLAND & WALES)

 ~ (ALSO
ADMITTED IN ILLINOIS)

 * (ALSO ADMITTED IN NEW
YORK)

 REGISTERED FOREIGN
LAWYERS

 Z. JULIE GAO (CALIFORNIA)

 42/F, EDINBURGH TOWER, THE LANDMARK

15 QUEEN’S ROAD CENTRAL, HONG KONG

 TEL: (852) 3740-4700

FAX: (852) 3740-4727

www.skadden.com

April 22, 2019

 AFFILIATE OFFICES

 BOSTON

CHICAGO

 HOUSTON

LOS ANGELES

 NEW YORK

PALO ALTO

 WASHINGTON, D.C.

WILMINGTON

 BEIJING

BRUSSELS

 FRANKFURT

LONDON

 MOSCOW

MUNICH

 PARIS

SÃO PAULO

 SEOUL

SHANGHAI

 SINGAPORE

TOKYO

 TORONTO

 VIA EDGAR

 Ms. Mara
Ransom

 Ms. Jennifer López-Molina

Ms. Jennifer Thompson

 Ms. Myra Moosariparambil

Division of Corporation Finance

 Office of Consumer Products

U.S. Securities and Exchange Commission

 100 F Street, NE

Washington, D.C., 20549

Re:
 Yunji Inc.

 Registration Statement on Form F-1

 CIK No. 0001759614

 Dear Ms. Ransom, Ms. López-Molina, Ms. Thompson and Ms. Moosariparambil:

On behalf of our client, Yunji Inc., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”),
we are filing herewith the Company’s Amendment No. 2 to the registration statement on Form F-1 (the “Registration Statement”) containing the preliminary prospectus with the price
range and certain recent developments 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 April 10, 2019.

 Securities and Exchange Commission

April 22, 2019

  Page
 2

 The Company respectfully advises the Commission that the Company plans to commence the road
show for the proposed offering on or about April 23, 2019. In addition, the Company plans to request that the Staff declare the effectiveness of the Registration Statement as on or about on May 2, 2019, 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.

*
*            *

 Securities and Exchange Commission

April 22, 2019

  Page
 3

 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:
 Shanglue Xiao, Chairman of the Board of Directors and Chief Executive Officer, Yunji Inc.

 Chen Chen, Chief Financial Officer, Yunji Inc.

Derek Shao, Partner, PricewaterhouseCoopers Zhong Tian LLP

Chris K.H. Lin, Esq., Partner, Simpson Thacher & Bartlett LLP

Daniel Fertig, Esq., Partner, Simpson Thacher & Bartlett LLP