Withdrawal Request

September 30, 2019

VIA EDGAR

Division of Corporation Finance

Office of Telecommunications

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549


Attn:	Joshua Shainess
	Celeste M. Murphy

	Re:	The We Company
		Request for Withdrawal of Registration Statement on Form S-1
		File No. 333-233259

Ladies and Gentlemen:

On August 14, 2019, The We Company (the “Company”) initially filed Registration Statement No. 333-233259 on Form S-1 (together with the exhibits and amendments thereto, the “Registration Statement”) with the Securities and Exchange Commission (the “Commission”).

Pursuant to Rule 477 under the Securities Act of 1933, as amended (the “Securities Act”), the Company hereby requests that the Commission consent to the withdrawal of the Registration Statement effective as of the date hereof. The Company is seeking withdrawal of the Registration Statement because it no longer wishes to conduct a public offering of securities at this time. The Registration Statement has not been declared effective by the Commission and no securities have been issued or sold under the Registration Statement. Based on the foregoing, the Company submits that the withdrawal of the Registration Statement is consistent with the public interest and the protection of investors, as contemplated by Rule 477(a).

The Company acknowledges that no refund will be made for fees paid to the Commission in connection with the filing of the Registration Statement. However, in accordance with Rule 457(p) under the Securities Act, the Company requests that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.

If you have any questions, please contact the Company’s legal counsel, Ryan J. Dzierniejko of Skadden, Arps, Slate, Meagher & Flom LLP, at (212) 735-3712.


Very truly yours,


THE WE COMPANY


By:		/s/ Jared DeMatteis
Name:		Jared DeMatteis
Title:		Deputy Chief Legal Officer