Simpson Thacher & Bartlett
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September 19, 2017
VIA EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Ms. Anny Nguyen Parker
Mr. Donald E. Field
Mr. J. Nolan McWilliams
Ms. Amy Geddes
Ms. Theresa Brillant
Re: BEST Inc.
Amendment No. 4 to Registration Statement on Form F-1
File Number: 333-218959
Ladies and Gentlemen:
On behalf of our client, BEST Inc., an exempted company organized under the laws of the Cayman Islands (the “Company”), we enclose herewith for filing via EDGAR with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, Amendment No. 6 (“Amendment No. 6”) to the Company’s above-referenced registration statement on Form F-1 (the “Registration Statement”).
We enclose herewith ten (10) courtesy copies of Amendment No. 6, which has been marked to show changes to the Registration Statement filed with the Commission on September 6, 2017 (the “September 6 Filing”).
DANIEL FERTIG ADAM C. FURBER 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 SEOUL TOKYO WASHINGTON, D.C.
The Company has revised the September 6 Filing to (i) reduce the number of Class A ordinary shares, represented by American depositary receipts, to be offered in its initial public offering, (i) to adjust down the estimated range of the offering price for its initial public offering and (iii) to disclose a material indication of interest received in its initial public offering, as well as make related updates to the disclosure.
The Company expects to price its initial public offering today, September 19, 2017 and, along with the underwriters, has submitted a request to the staff of the Commission pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933 to request that the effectiveness of the above-referenced registration statement (the “F-1 Registration Statement”) be accelerated to, and that the F-1 Registration Statement become effective at, at, 4:00 P.M., Eastern Daylight Time today, September 19, 2017, or as soon as practicable thereafter.
We greatly appreciate the Staff’s cooperation with the Company to achieve this offering timetable.
* * * * *
If you have any questions regarding Amendment No. 6, please do not hesitate to contact me at +852 2514-7650 (office) or clin@stblaw.com (e-mail), or my colleagues Daniel Fertig at +852 2514-7660 (office) or dfertig@stblaw.com (e-mail) or Yi Gao at +852 2514-7620 (office) or ygao@stblaw.com (e-mail).
Questions pertaining to accounting and auditing matters should be directed to John Qian at +86 21 2228-3106 of Ernst & Young Hua Ming LLP, the independent registered public accounting firm of the Company.
| Very truly yours, |
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| /s/ Chris K.H. Lin |
| Chris K.H. Lin |
Enclosures
cc: Shao-Ning Johnny Chou, Chairman and Chief Executive Officer
Lei Guo, Chief Accounting Officer and Vice President of Finance
BEST Inc.
Daniel Fertig
Yi Gao
Brian Mathes
Simpson Thacher & Bartlett LLP
Yilong Du
Latham & Watkins LLP
John Qian
Ernst & Young Hua Ming LLP