ZTO Express (Cayman) Inc.
Building One, No. 1685 Huazhi Road
Qingpu District, Shanghai 201708
People's Republic of China
October 24, 2022
VIA EDGAR
Mr. Karl Hiller
Ms. Lily Dang
Mr. John Cannarella
Office of Energy & Transportation
Division of Corporate Finance
100 F Street, NE
Washington, D.C., 20549
| Re: | ZTO Express (Cayman) Inc. (the “Company”) |
| | Form 20-F for the Fiscal Year Ended December 31, 2021 |
| | Filed April 28, 2022 |
| | File No. 001-37922 |
Dear Mr. Hiller, Ms. Dang and Mr. Cannarella,
The Company has received the letter dated September 15, 2022 from the staff of the Securities and Exchange Commission (the “Commission”) regarding the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2021 filed with the Commission on April 28, 2022 (the “2021 Form 20-F”). The Company respectfully submits to request an extension to the deadline for responding to the letter due to additional time needed to prepare a thorough response. The Company will provide its response to the letter via EDGAR as soon as possible, in any event no later than November 4, 2022.
If you have any additional questions or comments regarding the 2021 Form 20-F, please contact the undersigned at +86 21 5980 4508 or the Company’s U.S. counsel, Haiping Li of Skadden, Arps, Slate, Meagher & Flom LLP at +86 21 6193 8210 or haiping.li@skadden.com, or Yuting Wu of Skadden, Arps, Slate, Meagher & Flom LLP at +86 21 6193 8225 or yuting.wu@skadden.com. Thank you very much.
| Very truly yours, |
| |
| /s/ Huiping Yan |
| Huiping Yan |
| Chief Financial Officer |
cc: | Meisong Lai, Chairman of the Board of Directors and Chief Executive Officer, ZTO Express (Cayman) Inc. |
| Haiping Li, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP |
| Yuting Wu, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP |
| Anna Li, Partner, Deloitte Touche Tohmatsu Certified Public Accountants LLP |