SIMPSON THACHER & BARTLETT
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+852 2514-7660 | dfertig@stblaw.com |
November 19, 2019
CONFIDENTIAL AND VIA EDGAR AND HAND DELIVERY
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Andrew Blume, Staff Accountant
Jennifer Thompson, Accounting Branch Chief
Re: Alibaba Group Holding Limited
Form 20-F for the Fiscal Year Ended March 31, 2019
Filed June 5, 2019
File No. 1-36614
Ladies and Gentlemen:
On behalf of our client Alibaba Group Holding Limited (the “Company”), we are submitting this letter in response to your follow-up correspondence dated November 5, 2019 (the “November 5 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission on June 5, 2019.
In the November 5 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff when the Company will respond. The Company respectfully advises the Staff that it continues to work on its responses and that it will require additional time in order to respond fully to your letter.
The Company is therefore requesting an extension until December 4, 2019 (ten business days from the date of this request) and expects to respond no later than that date and will endeavor to respond earlier if possible.
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DANIEL FERTIG | ADAM C. FURBER | MAKIKO HARUNARI | IAN C. HO | 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 | TOKYO | WASHINGTON, D.C. |
In the meantime, please do not hesitate to contact me at +852-2514-7660 (work) or dfertig@stblaw.com (email).
| Very truly yours, |
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| /s/ Daniel Fertig |
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| Daniel Fertig |
cc: Daniel Yong Zhang, Chief Executive Officer
Maggie Wei Wu, Chief Financial Officer
Timothy A. Steinert, General Counsel and Secretary
Alibaba Group Holding Limited