Simpson Thacher & Bartlett | ||||
ICBC TOWER, 35TH FLOOR 3 GARDEN ROAD HONG KONG
| ||||
TELEPHONE: +852-2514-7600 FACSIMILE: +852-2869-7694 | ||||
Direct Dial Number (852) 2514-7620 | E-mail Address ygao@stblaw.com |
August 17, 2020
CONFIDENTIAL AND VIA EDGAR
Office of Technology
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 4561
Washington, D.C. 20549
Attention: Mr. Robert Littlepage, Accounting Branch Chief
Mr. Joseph Kempf, Staff Accountant
Ms. Jan Woo, Esq., Legal Branch Chief
Mr. Michael C. Foland, Esq., Attorney-Advisor
Re: Yalla Group Limited
Draft Registration Statement on Form F-1
Submitted June 2, 2020
CIK No. 0001794350
Ladies and Gentlemen:
On behalf of our client, Yalla Group Limited, an exempted company incorporated under the laws of the Cayman Islands with limited liability (the “Company”), we hereby submit to the Securities and Exchange Commission (the “Commission”) a revised draft (“Draft No. 3”) of the above-referenced Draft Registration Statement on Form F-1 (the “Draft Registration Statement”).
For your easy reference, we are providing you by overnight delivery five (5) copies of this letter as well as Draft No. 3, which has been marked to show changes to the Company’s Draft Registration Statement confidentially submitted to the Commission on June 2, 2020.
The Company has included in Draft No. 3 its interim consolidated financial statements as of June 30, 2020 and for the six months ended June 30, 2020 and 2019, as well as certain other updated disclosures.
DANIEL FERTIG | ADAM C. FURBER | YI GAO | ADAM S. GOLDBERG | MAKIKO HARUNARI | JONATHAN HWANG | IAN C. HO | ANTHONY D. KING | CELIA C.L. LAM | CHRIS K.H. LIN | JIN HYUK PARK | KATHRYN KING SUDOL | CHRISTOPHER K.S. WONG |
RESIDENT PARTNERS
SIMPSON THACHER & BARTLETT, HONG KONG IS AN AFFILIATE OF SIMPSON THACHER & BARTLETT LLP WITH OFFICES IN: | ||||||||||||||||
NEW YORK | BEIJING | HOUSTON | LONDON | LOS ANGELES | PALO ALTO | SÃO PAULO | TOKYO | WASHINGTON, D.C. |
Simpson Thacher & Bartlett | ||
August 17, 2020 |
In response to the Staff’s verbal comment conveyed to us on June 19, 2020, the Company has disclosed the identity of the two audio streaming solutions providers engaged by the Company on page 95 of Draft No. 3.
If you have any question regarding the Draft Registration Statement, please do not hesitate to contact me at +852-2514-7620 (work), +852-6588-7136 (mobile) or ygao@stblaw.com (email) or Kai Fan at +852-2514-7515 (work), +852-6139-9879 (mobile) or kfan@stblaw.com (email).
Questions pertaining to auditing matters may also be directed to Enid Yang at +86-10-8508-7816 (work) or enid.yang@kpmg.com (email) of KPMG Huazhen LLP, the independent registered public accounting firm of the Company.
Very truly yours, |
/s/ Yi Gao |
Yi Gao |
Enclosures
cc: | Yalla Group Limited | |
Tao Yang, Chairman and Chief Executive Officer | ||
Simpson Thacher & Bartlett LLP | ||
Kai Fan | ||
Cleary Gottlieb Steen & Hamilton LLP | ||
Shuang Zhao | ||
KPMG Huazhen LLP | ||
Enid Yang |
2