CORRESP 1 filename1.htm

 

BILIBILI INC.

 

March 23, 2018

 

VIA EDGAR

 

Mr. Jeff Kauten

Ms. Folake Ayoola

Mr. Stephen Krikorian

Ms. Morgan Youngwood

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 

Re:                             Bilibili Inc. (CIK No. 0001723690)

Registration Statement on Form F-1 (Registration No. 333-223405)

Registration Statement on Form 8-A (Registration No. 001-38429)

 

Dear Ladies and Gentlemen:

 

Pursuant to Rule 461 of Regulation C (“Rule 461”) promulgated under the Securities Act of 1933, as amended, Bilibili Inc. (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, 4:00 p.m., Eastern Daylight Time on March 27, 2018, 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, covering the American depositary shares representing ordinary shares of the Company, be declared effective concurrently with the F-1 Registration Statement (the F-1 Registration Statement, together with the Registration Statement on Form 8-A, the “Registration Statements”).

 

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, Skadden, Arps, Slate, Meagher & Flom LLP.

 

The Company understands that Morgan Stanley & Co. International plc, Merrill Lynch, Pierce, Fenner & Smith Incorporated and J.P. Morgan Securities LLC, on behalf of the prospective underwriters of the offering, have joined in this request in a separate letter filed with the Securities and Exchange Commission today.

 

[Signature page follows]

 


 

 

Very truly yours,

 

 

 

 

 

 

 

Bilibili Inc.

 

 

 

 

 

 

 

By:

/s/ Rui Chen

 

 

Name:

Rui Chen

 

 

Title:

Chairman of the Board of Directors and Chief Executive Officer

 

[Signature Page to Issuer Acceleration Request]