VIA EDGAR
Ms. Kathleen Krebs
Special Counsel
Mr. Joshua Shainess
Attorney-Adviser
Mr. Terry French
Accountant Branch Chief
Ms. Christie Wong
Staff Accountant
Division of Corporation Finance
Office of Telecommunications
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
November 22, 2019
Re: YX Asset Recovery Limited (CIK No. 0001752234)
Registration Statement on Form F-1 (File No. 333-234302)
Registration Statement on Form 8-A (File No. 001-39133)
Request for Withdrawal
Ladies and Gentlemen:
Pursuant to Rule 477 under the Securities Act of 1933, as amended (the “Securities Act”), YX Asset Recovery Limited (the “Company”) hereby requests the immediate withdrawal of the Company’s Registration Statement on Form F-1 (File No. 333-234302), together with all amendments and exhibits thereto (collectively, the “Registration Statement”), effective as of the date hereof or at the earliest practicable date hereafter. The Registration Statement was originally filed with the Securities and Exchange Commission (the “Commission”) on October 23, 2019.
The Company submits this request for withdrawal as it does not intend to pursue the contemplated public offering of the securities covered by the Registration Statement at this time. The Company confirms that the Registration Statement has not been declared effective, and no securities have been or will be issued or sold pursuant to the Registration Statement.
The Company further requests that, in accordance with Rule 457(p) of the Securities Act, all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.
In addition, the Company requests the withdrawal of the Company’s Registration Statement on Form 8-A (File No. 001-39133), originally filed with the Commission on November 12, 2019, effective as of the date hereof or at the earliest practicable date hereafter.
Should any member of the staff of the Commission have any questions or comments with respect to this request, please contact our counsel, Paul Hastings LLP, attention: Jason Kuo at 852-2867-1289.
| Very truly yours, | ||
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| YX Asset Recovery Limited | ||
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| By: | /s/ Man Tan | |
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| Name: | Man Tan |
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| Title: | Chief Executive Officer and Chairman of the Board |
cc: Man Tan, Chief Executive Officer, YX Asset Recovery Limited
Jia Yan, Partner, Paul Hastings LLP
Jason Kuo, Partner, Paul Hastings LLP