China Index Holdings Limited
Tower A, No. 20 Guogongzhuang Middle Street
Fengtai District, Beijing 100070
The Peoples Republic of China
May 28, 2019
VIA EDGAR
Ms. Melissa Walsh
Mr. Stephen Krikorian
Mr. Donald Field
Mr. Justin Dobbie
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
U.S.A.
Re: |
China Index Holdings Limited (CIK No. 0001749797) |
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Registration Statement on Form F-1 (Registration No.: 333-231376) |
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Registration Statement on Form 8-A (Registration No.: 001-38917) |
Ladies and Gentlemen:
Pursuant to Rule 461 of Regulation C (Rule 461) promulgated under the Securities Act of 1933, as amended, China Index Holdings Limited (the Company) hereby requests that the effectiveness of the above-referenced Registration Statement on Form F-1, as amended (the F-1 Registration Statement), be accelerated to, and that the F-1 Registration Statement become effective at, 4:00 P.M., Eastern Time on May 30, 2019, or as soon thereafter as practicable.
The Company also requests that the Registration Statement on Form 8-A under the Securities Exchange Act of 1934, as amended, covering the American depositary shares representing ordinary shares of the Company, be declared effective concurrently with the F-1 Registration Statement (the F-1 Registration Statement, together with the Registration Statement on Form 8-A, the Registration Statements).
In connection with this request, the Company hereby acknowledges that:
· should the Commission or the Staff of the Commission (the Staff), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
· the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If there is any change in the acceleration requests set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461. Such request may be made by an executive officer of the Company or by any attorney from the Companys U.S. counsel, Wilson Sonsini Goodrich & Rosati, Professional Corporation.
[Signature page follows]
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Very truly yours, | |
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China Index Holdings Limited | |
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By: |
/s/ Vincent Tianquan Mo |
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Name: Vincent Tianquan Mo | |
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Title: Chairman of Board of Directors |