0001104659-14-079013.txt : 20141210 0001104659-14-079013.hdr.sgml : 20141210 20141110164908 ACCESSION NUMBER: 0001104659-14-079013 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20141110 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Sky Solar Holdings, Ltd. CENTRAL INDEX KEY: 0001594124 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-ENGINEERING SERVICES [8711] IRS NUMBER: 000000000 STATE OF INCORPORATION: E9 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: SUITE 1604 9 QUEEN'S ROAD, CENTRAL CITY: HONG KONG STATE: F4 ZIP: 00000 BUSINESS PHONE: 852-2107-3188 MAIL ADDRESS: STREET 1: SUITE 1604 9 QUEEN'S ROAD, CENTRAL CITY: HONG KONG STATE: F4 ZIP: 00000 FORMER COMPANY: FORMER CONFORMED NAME: Sky Power Holdings Ltd. DATE OF NAME CHANGE: 20131212 CORRESP 1 filename1.htm

 

Sky Solar Holdings, Ltd.

Suite 1604, 9 Queen’s Road, Central
Hong Kong Special Administrative Region
People’s Republic of China

 

November 10, 2014

 

VIA EDGAR

 

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

U.S.A.

 

Attention:                                         Mr. Jay Ingram, Legal Branch Chief

Ms. Sherry Haywood, Staff Attorney

 

Re:                                   Sky Solar Holdings, Ltd.

Registration Statement on Form F-1, as amended (File No. 333-198817)

Registration Statement on Form 8-A (Registration No. 001-36703)

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 of Regulation C (“Rule 461”) promulgated under the Securities Act of 1933, as amended, Sky Solar Holdings, Ltd. (the “Company”) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1 (the “F-1 Registration Statement”) be accelerated to, and that the Registration Statement become effective at 4:30 p.m. (Eastern Time), on November 10, 2014 or as soon thereafter as practicable.

 

The Company also requests that the Registration Statement on Form 8-A under the Securities Exchange Act of 1934, as amended, covering the American depositary shares representing ordinary shares of the Company (the “Registration Statement on Form 8-A,” together with the F-1 Registration Statement, the “Registration Statements”), be declared effective immediately following the F-1 Registration Statement.

 

If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel, Shearman & Sterling LLP.

 

The Company understands that Roth Capital Partners, LLC, on behalf of the prospective underwriters of the offering, have joined in this request in a separate letter delivered to you today.

 

The Company hereby acknowledges the following:

 


 

1.                                      should the Securities and Exchange Commission (the “Commission”) or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 

2.                                      the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 

3.                                      the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

[Signature page follows]

 


 

 

Very truly yours,

 

 

 

Sky Solar Holdings, Ltd.

 

 

 

 

 

 

 

By:

/s/ Amy (Yi) Zhang

 

 

Name:   Amy (Yi) Zhang

 

 

Title:     Chief executive officer and director

 

 

cc:                    Shuang Zhao

Shearman & Sterling LLP