SKADDEN, ARPS, SLATE, MEAGHER & FLOM | ||||
PARTNERS GEOFFREY CHAN * SHU DU * ANDREW L. FOSTER * CHI T. STEVE KWOK * EDWARD H.P. LAM ◆* HAIPING LI * RORY MCALPINE ◆ JONATHAN B. STONE * KAI SUN PALOMA P. WANG ◆ (ALSO ADMITTED IN ENGLAND & WALES) * (ALSO ADMITTEDIN NEW YORK) | 世達國際律師事務所 42/F, EDINBURGH TOWER, THE LANDMARK 15 QUEEN’S ROAD CENTRAL, HONG KONG
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BEIJING BRUSSELS FRANKFURT LONDON MUNICH PARIS SÃO PAULO SEOUL SHANGHAI SINGAPORE TOKYO TORONTO | ||
May 19, 2023
Ms. Taylor Beech
Division of Corporation Finance
Office of Trade and Services
U.S. Securities and Exchange
Commission
100 F Street, NE
Washington, D.C. 20549
| Re: | NaaS Technology Inc. |
(CIK Number: 000 1712178)
Registration Statement on Form F-1
Dear Ms. Beech:
On behalf of our client, NaaS Technology Inc., a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are hereby filing Amendment No. 1 to the Company’s registration statement on Form F-1 (the “Registration Statement”) containing a preliminary prospectus with the estimated offering size and certain exhibits relating to a proposed registered direct offering in the United States of the Company’s Class A ordinary shares, par value US$0.01 per share, to be represented by American depositary shares (“ADSs”) via EDGAR to the Securities and Exchange Commission (the “Commission”).
The Company intends to file an acceleration request on May 22, 2023 to request that the staff of the Commission (the “Staff”) declare effectiveness of the Registration Statement on or about May 24, 2023. The Company would greatly appreciate the Staff’s continuing assistance and support to the Company in meeting the proposed timetable for the offering.
* * *
Registration Statement
Securities and Exchange Commission
May 19, 2023
Page 2
If you have any questions regarding the Registration Statement, please contact the undersigned, partner at Skadden, Arps, Slate, Meagher & Flom LLP, by phone at +852 3740 4858 or via e-mail at shu.du@skadden.com.
| Very truly yours, |
/s/ Shu Du |
| Shu Du |
| cc: | Mr. Alex Wu, Chief Financial Officer, NaaS Technology Inc. |
Ms. Christine JH Zhang, Partner, Ernst & Young Hua Ming LLP
