NEC Corporation
7-1, Shiba 5-chome, Minato-ku, Tokyo 108-8001, Japan Tel. +81-3-3454-1111 |
May 12, 2020
VIA EDGAR
Re: | NEC Corporation |
Request for Withdrawal of Registration Statement on Form20-F |
Filed March 17, 2020 |
File No. 000-12713 |
Michael C. Foland, Esq.
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Dear Mr. Foland:
NEC Corporation (“NEC” or the “Company”) hereby respectfully requests the withdrawal of its Registration Statement on Form20-F (FileNo. 000-12713) (the “Initial Registration Statement”) filed with the Securities and Exchange Commission (the “SEC”) on March 17, 2020, relating to the registration of NEC’s common stock under Section 12 of the U.S. Securities Exchange Act of 1934, as amended.
The Company is submitting this withdrawal request to avoid the automatic effectiveness of the Initial Registration Statement sixty (60) days after its initial filing. As the SEC staff (the “Staff”) has not completed its review of the Initial Registration Statement, the Company desires to prevent the Initial Registration Statement from becoming effective prior to completion of the Staff’s review. The Company intends to file a revised Registration Statement on Form20-F as soon as practicable in order to address comments previously provided by the Staff.
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Securities and Exchange Commission | 2 | May 12, 2020 |
Should the Staff have any questions or comments with respect to the foregoing, please contact our legal counsel, Takahiro Saito of Simpson Thacher & Bartlett LLP, at tsaito@stblaw.com.
Sincerely, |
/s/ Tetsuo Mukunoki |
Tetsuo Mukunoki |
General Manager, Legal Division, NEC Corporation |
cc: | Securities and Exchange Commission |
Larry Spirgel, Associate Director |
Frank Knapp, Staff Accountant |
Kathleen Collins, Accounting Branch Chief |
Simpson, Thacher & Bartlett LLP |
Takahiro Saito, Partner |