Correspondence 0001193125-24-166674 from WEBTOON Entertainment Inc. (WBTN) (CIK 0001997859) (WBTN)
WEBTOON Entertainment Inc. (WBTN) (CIK 0001997859)
Date: June 24, 2024 · CIK: 0001997859 · Accession: 0001193125-24-166674
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File numbers found in text: 333-279863
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CORRESP 1 filename1.htm CORRESP Goldman Sachs & Co. LLC 200 West Street New York, New York 10282 Morgan Stanley & Co. LLC 1585 Broadway New York, New York 10036 J.P. Morgan Securities LLC 383 Madison Avenue New York, New York 10179 Evercore Group L.L.C. 55 East 52nd Street, 35th Floor New York, NY 10055 June 24, 2024 VIA EDGAR Securities and Exchange Commission Division of Corporate Finance 100 F Street, NE Washington, D.C. 20549 Attention: Stephany Yang, Anne McConnell, Erin Donahue and Evan Ewing Re: WEBTOON Entertainment Inc. Registration Statement on Form S-1 Filed May 31, 2024, as amended File No. 333-279863 Ladies and Gentlemen: In accordance with 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 WEBTOON Entertainment Inc. (the “Company”) that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 2:00 p.m. New York City time on Wednesday, June 26, 2024 or as soon thereafter as practicable, or at such other time thereafter as the Company or its outside counsel, Kirkland & Ellis LLP, may request by telephone to the staff of the U.S. Securities and Exchange Commission. Pursuant to Rule 460 under the Act, we, as representatives of the several underwriters, wish to advise you that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of securities, as many copies of the preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus. We, the undersigned, as representatives of the several underwriters, 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 Morgan Stanley & Co. LLC J.P. Morgan Securities LLC Evercore Group L.L.C. as representatives of the several underwriters Goldman Sachs & Co. LLC By: /s/ Charlie Black Name: Charlie Black Title: Managing Director Morgan Stanley & Co. LLC By: /s/ Aderike Ajao Name: Aderike Ajao Title: Vice President J.P. Morgan Securities LLC By: /s/ Beau Freker Name: Beau Freker Title: Executive Director Evercore Group L.L.C. By: /s/ Zaheed Kajani Name: Zaheed Kajani Title: Senior Managing Director