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
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File numbers found in text: 333-274353
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CORRESP
1
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