ROTH CAPITAL PARTNERS, LLC
888 San Clemente Drive Suite 400
Newport Beach, California 92660
United States of America
As representative of the underwriters
VIA EDGAR
September 28, 2020
Mr. Blaise Rhodes
Mr. Rufus Decker
Ms. Cara Wirth
Ms. Erin Jaskot
Office of Telecommunications
Division of Corporation Finance
Securities and Exchange
Commission 100 F Street, N.E.
Washington, D.C. 20549
Re: | Boqii Holding Limited (the “Company”) |
Registration Statement on Form F-1, as amended (Registration No. 333-248641) |
Registration Statement on Form 8-A (Registration No. 001-39547) |
Dear Ladies and Gentlemen:
We hereby join the Company’s request for acceleration of the above-referenced Registration Statements, requesting effectiveness at 4:00 p.m., Eastern Standard Time on September 29, 2020, 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 September 23, 2020 and the date hereof, copies of the Company’s preliminary prospectus dated September 22, 2020 were distributed as follows:
More than 1,300 copies to prospective underwriters, institutional investors, dealers and others.
The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[Signature page follows]
Very truly yours,
ROTH CAPITAL PARTNERS, LLC
As representative of the underwriters
ROTH CAPITAL PARTNERS, LLC
By: | /s/ Aaron M. Gurewitz | |
Name: | Aaron M. Gurewitz | |
Title: | Head of Equity Capital Markets |
[Signature page to Acceleration Request]