Correspondence 0001104659-24-057650 from ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)
ZEEKR Intelligent Technology Holding Ltd (ZK) (CIK 0001954042)
Date: May 7, 2024 · CIK: 0001954042 · Accession: 0001104659-24-057650
AI Filing Summary & Sentiment
File numbers found in text: 001-42042, 333-275427
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CORRESP
1
filename1.htm
May
7, 2024
VIA EDGAR
Mr. Charles Eastman
Mr. Hugh West
Mr. Bradley Ecker
Mr. Geoffrey Kruczek
Division of Corporation Finance
Office of Manufacturing
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
ZEEKR Intelligent Technology Holding Limited (CIK: 0001954042)
Registration Statement on Form F-1 (File No. 333-275427)
Registration Statement on Form 8-A (File No. 001-42042)
Ladies and Gentlemen:
In accordance with Rule 461
of the General Rules and Regulations under the Securities Act of 1933, as amended, ZEEKR Intelligent Technology Holding Limited (the “Company”)
hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended (the “Form F-1
Registration Statement”) be accelerated to and that the Registration Statement become effective at 4:00 p.m., Eastern Time,
on May 9, 2024, or as soon thereafter as practicable.
The Company also requests
that the Registration Statement on Form 8-A under the Securities Exchange Act of 1934, as amended, covering the American depositary shares
representing ordinary shares of the Company, be declared effective concurrently with the Form F-1 Registration Statement (the Form F-1
Registration Statement, together with the Registration Statement on Form 8-A, the “Registration Statements”).
If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. The request may be made
by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Davis Polk & Wardwell LLP.
The Company understands that
the representatives of the underwriters of the offering, have joined in this request in a separate letter filed with the Securities and
Exchange Commission (the “Commission”) today.
May
7, 2024
The Company hereby acknowledges
the following:
· should the Commission or the staff of the Commission (the “Staff”), acting pursuant
to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the
filing;
· the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing
effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the United States.
[Signature page follows]
Yours sincerely,
ZEEKR Intelligent Technology Holding Limited
By:
/s/ Conghui An
Name:
Conghui An
Title:
Director, Chief Executive Officer
[Signature Page to Issuer
Acceleration Request]