Advanced Semiconductor Engineering, Inc.
26 Chin Third Road
Nantze Export Processing Zone
Nantze, Kaohsiung, Taiwan
Republic of China
January 22, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, DC 20549
Re: | Acceleration Request for Advanced Semiconductor Engineering, Inc. Amendment No. 5 to Registration Statement on Form F-4 Filed January 16, 2018 File No. 333-214752 |
Ladies and Gentlemen :
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Advanced Semiconductor Engineering, Inc. (the “Company”) hereby respectfully requests that the effective date of the above referenced Registration Statement on Form F-4 be accelerated to 4:00 p.m. (EST) on Monday, January 22, 2018, or as soon thereafter as practicable.
If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statement on Form F-4 in accordance with Rule 461. The request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Davis Polk & Wardwell LLP.
The Company hereby acknowledges that: (i) should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| Very truly yours, Advanced Semiconductor Engineering, Inc. By:/s/ Joseph Tung Name: Joseph Tung Title: Chief Financial Officer |
cc: James C. Lin
Davis Polk & Wardwell LLP