CONFIDENTIAL | November 14, 2016 |
Mr. Brian Soares
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Dear Mr. Soares:
On behalf of our client, Minebea Co., Ltd. (the “Company”), a company incorporated under the laws of Japan, we are submitting the Company’s Registration Statement on Form F-4 (the “Registration Statement”) relating to a business integration of the Company with MITSUMI ELECTRIC CO., LTD. through a share exchange.
If you have any questions regarding the Registration Statement, please contact me at mikeda@shearman.com, +81-3-5251-1601, or Toshiro Mochizuki at toshiro.mochizuki@shearman.com,+81-3-5251-0210.
Thank you for your time and attention.
Very truly yours, |
/s/ Masahisa Ikeda |
Masahisa Ikeda |
Managing Partner |
Enclosures
cc: | Mr. Yoshihisa Kainuma, Representative Director, President and Chief Executive Officer, Minebea Co., Ltd. |