New York Northern California Washington DC São Paulo London | Paris Madrid Tokyo Beijing Hong Kong | |
Manuel Garciadiaz
| ||
Davis Polk & Wardwell LLP 450 Lexington Avenue | 212 450 6095 tel 212 450 6858 fax manuel.garciadiaz@davispolk.com | |
March 30, 2020 | |
Re: | Vitru Limited Submitted March 30, 2020 |
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Ladies and Gentlemen:
On behalf of our client, Vitru Limited (the “Company”), an exempted company with limited liability incorporated under the laws of the Cayman Islands, which was incorporated in March 2020, we have confidentially submitted a draft registration statement on Form F-1 (the “Draft Registration Statement”) relating to a proposed initial public offering ( “IPO”) of the Company’s common shares via EDGAR to the Securities and Exchange Commission (the “Commission”) for confidential review pursuant to the Jumpstart Our Business Startups Act (the “JOBS Act”). For the staff’s convenience, we have also enclosed three copies of the Draft Registration Statement, as confidentially submitted on EDGAR. The Company confirms that it is an “emerging growth company”, as defined in the JOBS Act and its securities have not been previously sold pursuant to an effective registration statement under the Securities Act of 1933, as amended.
A formal filing of the Registration Statement will be made at a later date, which in no event will be later than 15 days before the Company commences its road show.
Please do not hesitate to contact me at 212-450-6095 or manuel.garciadiaz@davispolk.com or Konstantinos Papadopoulos at 212-450-6189 or konstantinos.papadopoulos@davispolk.com if you have any questions regarding the foregoing or if I can provide any additional information.
Very truly yours,
/s/ Manuel Garciadiaz
Manuel Garciadiaz
cc: | Pedro Jorge Guterres Quintans Graça, Chief Executive Officer |
Carlos Henrique Boquimpani de Freitas, Chief Financial Officer
Vitru Limited
Leandro Camilo, Partner
PricewaterhouseCoopers Auditores Independentes