Correspondence 0001213900-23-065665 from Jinxin Technology Holding Co (NAMI) (CIK 0001967631) (NAMI)
Jinxin Technology Holding Co (NAMI) (CIK 0001967631)
Date: Aug. 10, 2023 · CIK: 0001967631 · Accession: 0001213900-23-065665
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CORRESP
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58th Floor, China World Tower A
No.1 Jian Guo Men Wai Avenue
Beijing 100004, P.R. China
Steve Lin
To Call Writer Directly
+8610 5737 9315
steve.lin@kirkland.com
Telephone: +8610 5737 9300
Facsimile: +8610 5737 9301
www.kirkland.com
August 10, 2023
VIA EDGAR
Mr. Robert Shapiro
Mr. Lyn Shenk
Ms. Rucha Pandit
Mr. Dietrich King
Office of Trade & Services
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re:
Jinxin Technology Holding Company
Registration Statement on Form F-1
CIK No. 0001967631
Dear Mr. Shapiro, Mr. Shenk, Ms. Pandit and Mr. King:
On behalf of our client, Jinxin Technology Holding
Company, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are
filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain
exhibits via EDGAR with the Securities and Exchange Commission (the “Commission”).
In accordance with the Jumpstart Our Business Startups
Act, as amended, the Company is, concurrently with the Registration Statement, filing the draft registration statement and all amendments
thereto that were previously submitted for the non-public review of the staff of the Commission (the “Staff”).
The Company plans to file an amendment to the Registration Statement containing the estimated price range and offering size, and to launch
the road show for the offering no earlier than 15 days after the date hereof, subject to market conditions and the review of the Staff.
The Company would greatly appreciate the Staff’s continuing assistance and support to the Company in meeting the proposed timetable
for the offering.
***
If you have any questions regarding the Registration
Statement, please contact me at steve.lin@kirkland.com, + 86 10 5737 9315 (work) or +86 18610495593 (cell), or Justin Zhou at justin.zhou@kirkland.com,
+ 86 10 5737 9323 (work) or +86 18614200658 (cell).
Thank you for your time and attention.
Very truly yours,
/s/ Steve Lin
Steve Lin
Licensed foreign lawyers only
Austin Bay Area Boston Brussels
Chicago Dallas Hong Kong Houston London Los Angeles Miami Munich New York Paris Salt Lake City Shanghai
Washington, D.C.
Office of Trade & Services
Division of Corporation Finance
U.S. Securities and Exchange Commission
August 10, 2023
Page 2
Enclosure
c.c.
Jin Xu, Chairman of the Board of Directors and Chief Executive Officer,
Jinxin Technology Holding Company
Jun Jiang, Director and Chief Operating Officer, Jinxin Technology
Holding Company
David Zhang, Esq., Partner, Kirkland & Ellis
Steve Lin, Esq., Partner, Kirkland & Ellis International LLP
Justin Zhou, Esq., Partner, Kirkland & Ellis International LLP
Patrick Wong, Partner, WWC Professional Corporation Limited
Ying Li, Esq., Partner, Hunter Taubman Fischer & Li LLC
Guillaume de Sampigny, Esq., Partner, Hunter Taubman Fischer &
Li LLC