April 3, 2017
VIA EDGAR &E-MAIL
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: J. Nolan McWilliams
Re: | Yum China Holdings, Inc. |
Post-Effective Amendment No. 1 to FormS-1 |
Filed March 9, 2017 |
FileNo. 333-213719 |
Ladies and Gentlemen:
Yum China Holdings, Inc. (the “Company”) is pleased to respond to the letter dated March 29, 2017 from the staff (the “Staff”) of the Securities and Exchange Commission with respect to Post-Effective Amendment No. 1 (“Post-Effective Amendment No. 1”) to the Company’s Registration Statement on FormS-1 (the “FormS-1”). Concurrently herewith, the Company has filed Post-Effective Amendment No. 2 (“Post-Effective Amendment No. 2”) to the FormS-1 incorporating the revision described herein. For the convenience of the Staff’s review, we have set forth below the comment contained in the Staff’s letter in italics followed by the Company’s response.
Incorporation of Certain Information by Reference, page 58
Staff Comment No. 1:
Please incorporate by reference your Current Report on Form8-K filed on March 10, 2017.
Company Response:
The Company has revised its disclosure in response to the Staff’s comment. Please see page 58 of Amendment No. 2.
If you would like to discuss the matters set forth herein, please contact me at + (86) 21 2407 7888 or shella.ng@yumchina.com.
Sincerely, |
/s/ Shella Ng |
Shella Ng |
Chief Legal Officer and Corporate Secretary |
Yum China Holdings, Inc. |