Citigroup Global Markets Inc.
388 Greenwich Street,
New York, NY 10013
UBS Securities LLC
1285 Avenue of the Americas
New York, New York 10019
As representatives of the prospective underwriters
VIA EDGAR
April 1, 2019
Office of Consumer Products
Division of Corporation Finance
U.S. Securities & Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Ms. Lisa Kohl, Esq.
Ms. Mara Ransom, Esq.
Ms. Katherine Bagley
Ms. Jennifer Thompson
Ms. Lisa Sellars
Re: Ruhnn Holding Limited (the “Company”)
Registration Statement on Form F-1, as amended (Registration No. 333-230082)
Registration Statement on Form 8-A (Registration No. 001-38852)
Ladies and Gentlemen:
We hereby join the Company’s request for acceleration of the above-referenced Registration Statements, requesting effectiveness for 4:00 p.m., Eastern Daylight Time on April 2, 2019, or as soon thereafter as is practicable.
Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended, we wish to advise you that between March 22, 2019 and the date hereof, 571 copies of the preliminary prospectus of the Company dated March 22, 2019 were distributed to underwriters, dealers, institutional investors and others.
We have been advised by the prospective underwriters that they have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[Signature page follows]
| Very truly yours, | |
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| As representatives of the prospective underwriters | |
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| CITIGROUP GLOBAL MARKETS INC. | |
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| By: | /s/ Kenneth Chow |
| Name: | Kenneth Chow |
| Title: | Managing Director |
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| UBS SECURITIES LLC | |
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| By: | /s/ Jake Ettore |
| Name: | Jake Ettore |
| Title: | Director |
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| By: | /s/ Hasan Ali |
| Name: | Hasan Ali |
| Title: | Director |
[Underwriters Acceleration Request]
