Qudian Inc.
15/F Lvge Industrial Building
1 Datun
Chaoyang District, Beijing 100012
People’s Republic of China
+86-10-59485220
October 13, 2017
VIA EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Ms. Era Anagnosti, Esq., Legal Branch Chief | |
| Mr. Christopher Dunham, Esq., Staff Attorney | ||
| Mr. David Irving, Staff Accountant | ||
| Mr. Marc Thomas, Staff Accountant |
| Re: | Qudian Inc. (CIK No. 0001692705) |
| Registration Statement on FormF-1, as amended (FileNo. 333-220511) |
| Registration Statement on Form8-A (FileNo. 001-38230) |
Ladies and Gentlemen:
Pursuant to Rule 461 of Regulation C (“Rule 461”) promulgated under the Securities Act of 1933, as amended, Qudian Inc. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on FormF-1, as amended (the“F-1 Registration Statement”), be accelerated to, and that the Registration Statement become effective at, 4:00 P.M., Eastern Daylight Time on October 17, 2017, or as soon thereafter as practicable.
The Company also requests that the Registration Statement on Form8-A, as amended, under the Securities Exchange Act of 1933, as amended, covering the American depositary shares representing ordinary shares of the Company (the “Registration Statement on Form8-A,” together with theF-1 Registration Statement, the “Registration Statements”), be declared effective concurrently with theF-1 Registration Statement.
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 Statements in accordance with Rule 461. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Simpson Thacher & Bartlett LLP.
The Company understands that Morgan Securities & Co. International plc, Credit Suisse Securities (USA) LLC, Citigroup Global Markets Inc., China International Capital Corporation Hong Kong Securities Limited and UBS Securities LLC, on behalf of the prospective underwriters of the offering, have joined in this request in a separate letter delivered to you today.
[Signature page follows]
Very truly yours, | ||
Qudian Inc. | ||
| By: | /s/ Min Luo | |
| Name: | Min Luo | |
| Title: | Chairman and chief executive officer | |
