SKADDEN, ARPS, SLATE, MEAGHER & FLOM
PARTNERS | 世達國際律師事務所 | AFFILIATE OFFICES |
CHRISTOPHER W. BETTS | 42/F, EDINBURGH TOWER, THE LANDMARK |
|
WILL H. CAI ^ | 15 QUEEN’S ROAD CENTRAL, HONG KONG | BOSTON |
GEOFFREY CHAN * |
| CHICAGO |
ANDREW L. FOSTER * | TEL: (852) 3740-4700 | HOUSTON |
CHI T. STEVE KWOK * | FAX: (852) 3740-4727 | LOS ANGELES |
EDWARD H.P. LAM ¨* | www.skadden.com | NEW YORK |
HAIPING LI * | | PALO ALTO |
RORY MCALPINE ¨ | | WASHINGTON, D.C. |
CLIVE W. ROUGH ¨ | | WILMINGTON |
JONATHAN B. STONE * |
|
| BEIJING |
^ (ALSO ADMITTED IN CALIFORNIA) | BRUSSELS |
¨ (ALSO ADMITTED IN ENGLAND & WALES) | FRANKFURT |
* (ALSO ADMITTED IN NEW YORK) | LONDON |
| MOSCOW |
REGISTERED FOREIGN LAWYERS | MUNICH |
Z. JULIE GAO (CALIFORNIA) | PARIS |
BRADLEY A. KLEIN (ILLINOIS) | SÃO PAULO |
| SEOUL |
| SHANGHAI |
| | SINGAPORE |
| July 16, 2018 | TOKYO |
| | TORONTO |
VIA EDGAR
Jan Woo, Legal Branch Chief
David Edgar, Staff Accountant
Christine Dietz, Assistant Chief Accountant
Bernard Nolan, Attorney-Adviser
Barbara C. Jacobs, Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Pintec Technology Holdings Limited
Registration Statement on Form F-1
CIK No. 0001716338
Dear Ms. Woo, Mr. Edgar, Ms. Dietz, Mr. Nolan and Ms. Jacobs:
On behalf of our client, Pintec Technology Holdings Limited, a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we are filing herewith the Company’s registration statement on Form F-1 (the “Registration Statement”) and certain exhibits via EDGAR with the Securities and Exchange Commission (the “Commission”).
To facilitate your review, we have separately delivered to you today five courtesy copies of the Registration Statement, marked to show changes to the revised draft registration statement confidentially submitted on June 19, 2018. However, please note that we have left the entire section entitled “Description of American Depositary Shares” unmarked for ease of reading, even though the entire section has been replaced with a different draft since the revised draft registration statement confidentially submitted on June 19, 2018.
In accordance with the Jumpstart Our Business Startups Act, as amended, the Company plans to file an amendment to the Registration Statement containing the
estimated price range and offering size and launch the road show no earlier than 15 days after the date hereof.
If you have any questions regarding the Registration Statement, please contact the undersigned by phone at +852 3740-4863 or by e-mail at julie.gao@skadden.com, or Geoffrey Wang, the audit engagement partner at PricewaterhouseCoopers Zhong Tian LLP, by telephone at +86 10-6533-2928 or by email at geoffrey.wang@cn.pwc.com. PricewaterhouseCoopers Zhong Tian LLP is the independent registered public accounting firm of the Company.
| Very truly yours, |
| |
| |
| /s/ Z. Julie Gao |
| |
| Z. Julie Gao |
Enclosures
cc: Wei Wei, Chief Executive Officer, Pintec Technology Holdings Limited
Steven Yuan Ning Sim, Chief Financial Officer, Pintec Technology Holdings Limited
Geoffrey Wang, Partner, PricewaterhouseCoopers Zhong Tian LLP
Chris K.H. Lin, Esq., Simpson Thacher & Bartlett LLP
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