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SEC Company Response from Vasta Platform Ltd (CIK 0001792829) — Jul 29, 2020

Vasta Platform Ltd (CIK 0001792829)
Date: July 29, 2020 · CIK: 0001792829 · Accession: 0001193125-20-202252

AI Filing Summary & Sentiment

File numbers found in text: 333-239686

Date
July 29, 2020
Author
Legal Branch Chief
Form
CORRESP
Company
Vasta Platform Ltd (CIK 0001792829)

Letter

July 29, 2020

VIA EDGAR

Office of Financial Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attn:

Scott Anderegg, Staff Attorney

Erin Jaskot, Legal Branch Chief

Re:

Vasta Platform Limited

Registration statement on Form F-1, as amended (File No. 333-239686)

Ladies and Gentlemen:

Pursuant to 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 Vasta Platform Limited, an exempted company incorporated under the laws of the Cayman Islands with limited liability (the “Company”), that the effective date of the Company’s Registration Statement on Form F-1 (File No. 333-239686) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 4:00 pm, Eastern Time, on July 30, 2020, or as soon as practicable thereafter. We hereby authorize Grenfel S. Calheiros of Simpson Thacher & Bartlett LLP, counsel to the several underwriters, to modify or withdraw this letter orally.

Pursuant to Rule 460 under the Act, please be advised that we, as representatives of the several underwriters, anticipate that approximately 4650 copies of the preliminary prospectus have been or will be sent to underwriters, dealers, institutions, investors and others.

In connection with the distribution of the preliminary prospectus for the above referenced issue, the underwriters have confirmed that they have and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,
Goldman
Sachs & Co. LLC

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 July 29, 2020

VIA EDGAR

 Office of Financial Services

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C. 20549

Attn:

 Scott Anderegg, Staff Attorney

 Erin Jaskot,
Legal Branch Chief

Re:

 Vasta Platform Limited

 Registration
statement on Form F-1, as amended (File No. 333-239686)

 Ladies and Gentlemen:

Pursuant to 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 Vasta Platform Limited, an exempted company incorporated under the laws of the Cayman Islands with limited liability (the “Company”), that the effective date of the Company’s Registration Statement on
Form F-1 (File No. 333-239686) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement
will become effective at 4:00 pm, Eastern Time, on July 30, 2020, or as soon as practicable thereafter. We hereby authorize Grenfel S. Calheiros of Simpson Thacher & Bartlett LLP, counsel to the several underwriters, to modify or
withdraw this letter orally.

 Pursuant to Rule 460 under the Act, please be advised that we, as representatives of the several
underwriters, anticipate that approximately 4650 copies of the preliminary prospectus have been or will be sent to underwriters, dealers, institutions, investors and others.

In connection with the distribution of the preliminary prospectus for the above referenced issue, the underwriters have confirmed that they
have and will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Very truly yours,

 Goldman
Sachs & Co. LLC

 BofA Securities, Inc.

Morgan Stanley & Co. LLC

Itau BBA USA Securities, Inc.

 As
representatives of the several underwriters

 [Signature Pages Follow]

 Goldman Sachs & Co. LLC

 As a Representative of the Several Underwriters

 By:

 /s/ Facundo Vazquez

 Name:

Facundo Vazquez

 Title:

Managing Director

 BofA Securities, Inc.

 As a Representative of the Several Underwriters

 By:

 /s/ Bruno Saraiva

 Name:

Bruno Saraiva

 Title:

Authorized Signatory

 Morgan Stanley & Co. LLC

 As a Representative of the Several Underwriters

 By:

 /s/ Lúlica B. Rocha

 Name:

Lúlica B. Rocha

 Title:

Vice President

 Itau BBA USA Securities, Inc.

 As a Representative of the Several Underwriters

 By:

 /s/ Roderick Sinclair Greenlees

 Name:

Roderick Sinclair Greenlees

 Title:

Managing Director

 By:

 /s/ Ubiratan dos Santos Machado

 Name:

Ubiratan dos Santos Machado

 Title:

Managing Director