SKADDEN, ARPS, SLATE, MEAGHER & FLOM
PARTNERS |
世達國際律師事務所 |
AFFILIATE OFFICES | |
CHRISTOPHER W. BETTS |
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WILL H. CAI ^ |
42/F, EDINBURGH TOWER, THE LANDMARK |
BOSTON | |
GEOFFREY CHAN * |
15 QUEENS ROAD CENTRAL, HONG KONG |
CHICAGO | |
ANDREW L. FOSTER * |
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HOUSTON | |
BRADLEY A. KLEIN |
TEL: (852) 3740-4700 |
LOS ANGELES | |
CHI T. STEVE KWOK * |
FAX: (852) 3740-4727 |
NEW YORK | |
EDWARD H.P. LAM ¨* |
www.skadden.com |
PALO ALTO | |
HAIPING LI * |
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WASHINGTON, D.C. | |
RORY MCALPINE ¨ |
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WILMINGTON | |
CLIVE W. ROUGH ¨ |
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JONATHAN B. STONE * |
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BEIJING | |
^ (ALSO ADMITTED IN CALIFORNIA) |
BRUSSELS | ||
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FRANKFURT | |
¨(ALSO ADMITTED IN ENGLAND & WALES) |
LONDON | ||
(ALSO ADMITTED IN ILLINOIS) |
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MOSCOW | |
*(ALSO ADMITTED IN NEW YORK) |
MUNICH | ||
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PARIS | |
REGISTERED FOREIGN LAWYER |
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SÃO PAULO | |
Z. JULIE GAO (CALIFORNIA) |
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SEOUL | |
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SHANGHAI | |
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SINGAPORE | |
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TOKYO | |
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TORONTO | |
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September 21, 2018 |
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VIA EDGAR Mr. Robert Littlepage |
Re: |
Viomi Technology Co., Ltd (CIK No. 0001742770) | |
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Response to the Staffs Comments on | |
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Amendment No. 1 to Registration Statement on Form F-1 Filed on September 11, 2018 | |
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File No. 333-227063 |
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Dear Mr. Littlepage, Mr. Cascarano, Ms. Krebs and Mr. Fischer:
On behalf of our client, Viomi Technology Co., Ltd, a foreign private issuer organized under the laws of the Cayman Islands (the Company), we submit to the staff (the Staff) of the Securities and Exchange Commission (the Commission) this letter setting forth the Companys responses to the comments contained in the Staffs letter dated September 18, 2018 on the Companys Amendment No. 1 to Registration Statement on Form F-1 filed on September 11, 2018 (the Registration Statement) and certain exhibits via EDGAR.
Concurrently with the submission of this letter, the Company is publicly filing Amendment No. 2 to its registration statement on Form F-1 (the Revised Registration Statement) and certain exhibits via EDGAR with the Commission.
To facilitate your review, we have separately delivered to you today five courtesy copies of the Revised Registration Statement, marked to show changes to the Registration Statement.
The Staffs comments are repeated below in bold and are followed by the Companys responses. We have included page references in the Revised Registration Statement where the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Revised Registration Statement.
Amendment No. 1 to Form F-1
Prospectus Summary
Corporate History and Structure, page 3
1. Please revise the corporate chart on pages 6 and 71 that shows the companys structure after the offering to also disclose the percentage voting power held by the material beneficial owners and investors in the offering.
In response to the Staffs comment, the Company has inserted the relevant disclosure on pages 6 and 71 of the Revised Registration Statement.
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If you have any questions regarding the Revised Registration Statement, please contact the undersigned by phone at +86-21-6193-8210 or via e-mail at haiping.li@skadden.com.
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Very truly yours, |
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/s/Haiping Li |
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Haiping Li |
Enclosures.
cc: Xiaoping Chen, Chairman of the Board of Directors and Chief Executive Officer, Viomi Technology Co., Ltd
Shun Jiang, Chief Financial Officer, Viomi Technology Co., Ltd
Z. Julie Gao, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP
Alex Chan, Partner, PricewaterhouseCoopers Zhong Tian LLP
Shuang Zhao, Esq., Partner, Cleary, Gottlieb, Steen & Hamilton LLP