|
SKADDEN, ARPS, SLATE, MEAGHER & FLOM |
|
PARTNERS |
世達國際律師事務所 |
AFFILIATE OFFICES |
CHRISTOPHER W. BETTS |
42/F, EDINBURGH TOWER, THE LANDMARK |
|
WILL H. CAI ^ |
15 QUEENS ROAD CENTRAL, HONG KONG |
BOSTON |
GEOFFREY CHAN * |
|
CHICAGO |
ANDREW L. FOSTER * |
TEL: (852) 3740-4700 |
HOUSTON |
CHI T. STEVE KWOK * |
FAX: (852) 3740-4727 |
LOS ANGELES |
EDWARD H.P. LAM ¨* |
www.skadden.com |
NEW YORK |
HAIPING LI * |
|
PALO ALTO |
RORY MCALPINE ¨ |
|
WASHINGTON, D.C. |
CLIVE W. ROUGH ¨ |
|
WILMINGTON |
JONATHAN B. STONE * |
|
|
|
|
BEIJING |
^ (ALSO ADMITTED IN CALIFORNIA) |
|
BRUSSELS |
¨ (ALSO ADMITTED IN ENGLAND & WALES) |
FRANKFURT | |
* (ALSO ADMITTED IN NEW YORK) |
|
LONDON |
|
|
MOSCOW |
REGISTERED FOREIGN LAWYERS |
|
MUNICH |
Z. JULIE GAO (CALIFORNIA) |
|
PARIS |
BRADLEY A. KLEIN (ILLINOIS) |
|
SÃO PAULO |
|
|
SEOUL |
|
|
SHANGHAI |
|
|
SINGAPORE |
|
|
TOKYO |
|
|
TORONTO |
July 20, 2018
Confidential
Draft Registration Statement
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: |
|
Niu Technologies |
|
|
Confidential Submission of the Draft Registration Statement on Form F-1 |
Dear Sir/Madam,
On behalf of our client, Niu Technologies, a foreign private issuer organized under the laws of the Cayman Islands (the Company), we are hereby submitting a draft registration statement on Form F-1 (the Draft Registration Statement) relating to a proposed initial public offering in the United States of the Companys ordinary shares, par value US$0.0001 per share, to be represented by American depositary shares (ADSs) via EDGAR to the Securities and Exchange Commission (the Commission) for confidential review pursuant to the Jumpstart Our Business Startups Act, as amended (the JOBS Act). 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 registration statement on Form F-6 relating to the ADSs will be filed with the Commission in due course.
Financial Statements
The Company has included in this submission its audited consolidated financial statements as of December 31, 2016 and 2017 and for the two years ended December 31, 2017. As an emerging growth company, the Company has omitted its financial statements for 2015, and has also omitted the selected financial information for the years before 2016.
* * *
If you have any questions regarding the Draft Registration Statement, please contact the undersigned by phone at +852 3740-4863 or via e-mail at julie.gao@skadden.com, or Allen Lu, partner at KPMG Huazhen LLP, by telephone at +86 10 8508-7805 or via email at allen.lu@kpmg.com. KPMG Huazhen LLP is the independent registered public accounting firm of the Company.
|
Very truly yours, |
|
|
|
/s/ Z. Julie Gao |
|
Z. Julie Gao |
cc: |
|
Yan Li, Chairman of the Board of Directors and Chief Executive Officer, Niu Technologies |
|
|
Hardy Peng Zhang, Chief Financial Officer, Niu Technologies |
|
|
Allen Lu, Partner, KPMG Huazhen LLP |
|
|
David Zhang, Esq., Partner, Kirkland & Ellis International LLP |
|
|
Steve Lin, Esq., Partner, Kirkland & Ellis International LLP |