TELEPHONE: 852-2826-8688
PARTNERS WILLIAM Y. CHUA MICHAEL G. DESOMBRE KAY IAN NG CHUN WEI GWEN WONG |
28th Floor
WITH AFFILIATED OFFICES IN |
CONFIDENTIAL TREATMENT REQUESTED BY
FEISHANG ANTHRACITE RESOURCES LIMITED
December 24, 2013
Mr. John Reynolds,
Assistant Director,
Division of Corporation Finance,
Securities and Exchange Commission,
100 F Street, N.E.,
Washington, D.C., 20549,
U.S.A.
Re: Feishang Anthracite Resources Limited
Confidential Submission of
Revised Draft Registration Statement on Form 20-F
Dear Mr. Reynolds:
On behalf of Feishang Anthracite Resources Limited (the Company), we enclosed hereinwith a revised draft of the registration statement on Form 20-F (the Registration Statement), including a revised draft of the information statement (the Information Statement) to be distributed to the shareholders of China Natural Resources, Inc. (CHNR) in connection with the proposed spin-off of the Company by CHNR (the Spin-Off), which has been attached as Exhibit 15.1.
The revised draft of the Information Statement includes the revised draft of the listing document (the Hong Kong Listing Document) relating to the proposed listing of the Companys ordinary shares on The Stock Exchange of Hong Kong Limited (the Hong Kong Stock Exchange) in connection with the Spin-Off. The revised draft of the Hong Kong Listing Document reflects revisions made in response to the comments received from the Hong Kong Stock Exchange since the last submission of the draft registration statement to the staff (the Staff) of the Securities and Exchange Commission on December 20, 2013, and is in substantially the form submitted to the Hong Kong Stock Exchange on December 24, 2013, except for certain modifications as more fully described in the Information Statement.
* * *
Please direct any questions you may have to the undersigned (tel: 011-852-2826-8632; e-mail: chuaw@sullcrom.com) or Henry Li (tel: 011-852-2826-8677; e-mail: lih@sullcrom.com). Any correspondence or documents may also be faxed to our attention at 1-212-558-3588.
Questions pertaining to accounting and auditing matters may be directed to Bennett Wai (tel: 011-86-10-5815-3376; e-mail: bennett.wai@cn.ey.com) of Ernst & Young, the independent registered public accounting firm of the Company.
|
Sincerely yours, |
|
|
|
/s/ William Y. Chua p.p. |
|
William Y. Chua |
(Enclosures)
cc: Mr. Bonaventure M.W. Yue
Chief Financial Officer
(Feishang Anthracite Resources Limited)
Mr. Bennett Wai
(Ernst & Young)
Henry Li, Esq.
(Sullivan & Cromwell)
Ms. Erin Wilson
Mr. David Link
(Securities and Exchange Commission)