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Correspondence 0000950103-24-003401 from Vitru Brazil Ventures, Holdings & Trade Inc. (CIK 0001989305)

Vitru Brazil Ventures, Holdings & Trade Inc. (CIK 0001989305)
Date: March 4, 2024 · CIK: 0001989305 · Accession: 0000950103-24-003401

AI Filing Summary & Sentiment

File numbers found in text: 333-274353

Date
March 4, 2024
Author
Vitru Brasil Empreendimentos, Participações e Comércio S.A.
Form
CORRESP
Company
Vitru Brazil Ventures, Holdings & Trade Inc. (CIK 0001989305)

Letter

VIA EDGAR Office of Finance Division of Corporation Finance Attn: Nicholas Nalbantian Re: Vitru Brasil Empreendimentos, Participações e Comércio S.A. Registration Statement on Form F-4 File No. 333-274353

Dear Mr. Nalbantian:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Vitru Brasil Empreendimentos, Participações e Comércio S.A. (the “Company”) hereby requests that the effective date of the Company’s Registration Statement on Form F-4 (File No. 333-274353) (the “Registration Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective at 1 p.m., Eastern Standard Time, on March 6, 2024, or as soon as practicable thereafter. The Company hereby authorizes Manuel Garciadiaz of Davis Polk & Wardwell LLP, counsel to the Company, to modify or withdraw this request for acceleration orally.

The Company requests that we be notified of such effectiveness by a telephone call to Mr. Garciadiaz at +1 212 450-6095 and that such effectiveness also be confirmed in writing.

Very truly yours,
Vitru Brasil Empreendimentos, Participações e Comércio S.A.

Show Raw Text
CORRESP
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filename1.htm

March 4, 2024

VIA EDGAR

Office of Finance

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attn: Nicholas Nalbantian

 Re: Vitru Brasil Empreendimentos, Participações e Comércio S.A.

Registration Statement on Form F-4

File No. 333-274353

Dear Mr. Nalbantian:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended, Vitru Brasil Empreendimentos, Participações e Comércio S.A. (the “Company”)
hereby requests that the effective date of the Company’s Registration Statement on Form F-4 (File No. 333-274353) (the “Registration
Statement”) be accelerated by the Securities and Exchange Commission so that the Registration Statement will become effective
at 1 p.m., Eastern Standard Time, on March 6, 2024, or as soon as practicable thereafter. The Company hereby authorizes Manuel Garciadiaz
of Davis Polk & Wardwell LLP, counsel to the Company, to modify or withdraw this request for acceleration orally.

The Company requests that we be notified of such
effectiveness by a telephone call to Mr. Garciadiaz at +1 212 450-6095 and that such effectiveness also be confirmed in writing.

    Very truly yours,

    Vitru Brasil Empreendimentos, Participações e Comércio S.A.

    By:
    /s/ Carlos Henrique Boquimpani de Freitas

    Name:
    Carlos Henrique Boquimpani de Freitas

    Title:
    Chief Financial and Investor Relations Officer

    By:
    /s/ Ana Paula Rodrigues

    Name:
    Ana Paula Rodrigues

    Title:
    Chief People and Management and Services Officer