Correspondence 0001213900-26-008558 from Kyivstar Group Ltd. (KYIV)
Kyivstar Group Ltd.
Date: Jan. 28, 2026 · CIK: 0002062440 · Accession: 0001213900-26-008558
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File numbers found in text: 333-292996
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CORRESP 1 filename1.htm Kyivstar Group Ltd. Unit 517, Level 5 Index Tower Dubai (DIFC) United Arab Emirates January 28, 2026 VIA EDGAR AND E-MAIL United States Securities and Exchange Commission Division of Corporation Finance 100 F Street, N.E. Washington, D.C. 20549-6010 Attention: Jeff Kauten Re: Kyivstar Group Ltd. Registration Statement on Form F-1 (File No. 333-292996) Ladies and Gentlemen: In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended (the " Act "), we hereby request acceleration of the effective date of the Registration Statement on Form F-1 (File No. 333- 292996 ), as amended (the " Registration Statement ") of Kyivstar Group Ltd. (the " Company "). We respectfully request that the Registration Statement become effective as of 4:00 p.m., Eastern Time, on January 29, 2026, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Sidley Austin llp , by calling David Stewart at +44.20.7360.3780 or Jason Hyatt at +44.20.7360.2536 . Thank you for your assistance in this matter. [ signature page follows ] Very truly yours, KYIVSTAR GROUP LTD. By: /s/ Kaan Terzioğlu Name: Kaan Terzioğlu Title: Executive Chairman and Director cc: (via email) Zeze Ikhinmwin, Head of Legal J. David Stewart, Sidley Austin LLP Jason Hyatt, Sidley Austin LLP Jennifer Gascoyne, Latham & Watkins LLP