Simpson Thacher & Bartlett
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ICBC Tower, 35th Floor 3 Garden Road Hong Kong (852) 2514-7600
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| Facsimile (852) 2869-7694 | ||||
Direct Dial Number +852-2514-7650 | E-Mail Address CLIN@stblaw.com | |||
| August 31, 2015 | ||||
VIA EDGAR
Office of Transportation and Leisure
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Mr. John Dana Brown, Attorney Advisor |
| Mr. Donald E. Field, Attorney Advisor |
| Re: | 500.com Limited |
| Form 20-F for Fiscal Year Ended December 31, 2014 | |
| Filed April 27, 2015 | |
| File No. 001-36206 |
Gentlemen:
On behalf of our client, 500.com Limited, a company organized under the laws of the Cayman Islands (the “Company”), we are transmitting this letter in response to the comment received from the Staff (the “Staff”) of the Securities and Exchange Commission contained in the Staff’s letter dated August 21, 2015 (the “Comment Letter”), with respect to the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2014 (File No. 001-36206).
Set forth below is the Company’s response to the Staff’s comment in the Comment Letter. The Staff’s comment is retyped below for your ease of reference and are followed by the Company’s response.
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Leiming Chen Daniel Fertig Adam C. Furber Anthony D. King Celia C.L. Lam Chris K.H. Lin Jin Hyuk Park Kathryn King Sudol Christopher K.S. Wong Resident Partners
Simpson Thacher & Bartlett, Hong Kong is an affiliate of Simpson Thacher & Bartlett LLP with offices in: |
| New York | Beijing | Houston | London | Los Angeles | Palo Alto | São Paulo | Seoul | Tokyo | Washington, D.C. |
Simpson Thacher & Bartlett
General
| 1. | In January 2015, the Ministry of Commerce of China released a discussion draft of proposed legislation for public comment, which appears to set out a plan for overhauling Chinese foreign investment laws. To the extent that the discussion draft may be material to you or your operations please disclose the discussion draft, including how the proposed changes may impact your operations. In this regard, we note that neither the Risk Factors section on page 6 nor the Regulation of Our Industry section on page 54 reference or discuss this new proposed legislation. |
The Company acknowledges the Staff’s comment and respectfully advises the Staff that it will disclose the referenced draft legislation, how the proposed regulatory changes may impact its operations, and any recent developments with respect to the draft legislation in the Company’s next annual report on Form 20-F.
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Simpson Thacher & Bartlett
If you have any questions regarding this letter, please do not hesitate to contact me at +(852) 2514-7650 (work) orclin@stblaw.com (email).
| Very truly yours, | ||
| /s/ Chris K.H. Lin | ||
| Chris K.H. Lin | ||
| cc: | Zhengming Pan, President |
| Min Yu, Chief Financial Officer |