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26th Floor, Gloucester Tower The Landmark 15 Queen’s Road Central Hong Kong
Telephone: +852 3761 3300 Facsimile: +852 3761 3301
www.kirkland.com |
David Zhang To Call Writer Directly +852 3761 3318 david.zhang@kirkland.com |
September 23, 2020
| CONFIDENTIAL
Kathleen Krebs, Special Counsel Jeff Kauten, Staff Attorney Kathleen Collins, Accounting Branch Chief Melissa Kindelan, Staff Accountant
Office of Technology Division of Corporation Finance Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 |
VIA EDGAR
| Re: | Chindata Group Holdings Limited |
| Registration Statement on Form F-1 |
| File No. 333-248658 |
Dear Ms. Krebs, Mr. Kauten, Ms. Collins, Ms. Kindelan:
On behalf of our client, Chindata Group Holdings Limited
, a foreign private issuer incorporated under the laws of the Cayman Islands (the “Company”), we are filing herewith amendment No. 2 to the Company’s registration statement on Form F-1 (the “Registration Statement”) and exhibits via EDGAR to the Securities and Exchange Commission (the “Commission”). To facilitate your review, we have separately delivered to you four courtesy copies of the Registration Statement, marked to show changes to the registration statement filed with the Commission on September 18, 2020, and two copies of the submitted exhibits.
The Company advises the Staff that COVID-19 has not had a material adverse effect on the Company’s operations and construction projects. The Company also advises the Staff that all of the Company’s business with ByteDance is based in China and for the operations of ByteDance in China only. The Company believes that the ban of the TikTok app in India and the executive orders issued by U.S. President Donald J. Trump and the recent restrictions published by the U.S. Department of Commerce to potentially prohibit transactions with the TikTok app in the United States has not had a material adverse effect on the Company’s business and results of operations.
In addition, the Company respectfully advises the Staff that it will commence the roadshow for the proposed offering shortly after the date hereof, and expects to request acceleration of the effectiveness of the Registration Statement on or about September 29, 2020. The Company would appreciate the Staff’s timely assistance and support to the Company in meeting the proposed timetable for the offering.
| PARTNERS: Pierre-Luc Arsenault3 | Manas Chandrashekar6 | Lai Yi Chau | Justin M. Dolling6 | David Patrick Eich1,5,6 | Liu Gan2 | Karen K.Y. Ho | Damian C. Jacobs6 | Ka Man Lau | Guang Li3 | Neil E.M. McDonald | Kelly Naphtali | Ram Narayan3 | Amy Y.M. Ngan9 | Nicholas A. Norris6 | Paul S. Quinn | Michael D. Rackham6 | Richard C.C. Sharpe | Jesse D. Sheley# | Arthur K.H. Tso | Li Chien Wong | David Yun6 | Jacqueline B.N. Zheng3,6 REGISTERED FOREIGN LAWYERS: Michelle Cheh8 | Daniel Dusek3 | James A. Hill6 | David M. Irvine6 | Benjamin W. James4 | Cori A. Lable2 | Wei Yang Lim6 | Xiaoxi Lin3 | Yazhe Liu3 | Daniel A. Margulies6 | Mi Tang3 | Wenchen Tang3 | Liyong Xing3 | David Zhang3 ADMITTED IN: 1 State of Illinois (U.S.A.); 2 Commonwealth of Massachusetts (U.S.A.); 3 State of New York (U.S.A.); 4 State of Texas (U.S.A.); 5 State of Wisconsin (U.S.A.); 6 England and Wales; 7 Singapore; 8 Victoria (Australia); 9 New South Wales (Australia); # non-resident |
Office of Technology
Division of Corporation Finance
Securities and Exchange Commission
September 23, 2020
Page 2
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If you have any questions regarding the Registration Statement, please contact me at david.zhang@kirkland.com, +852 3761 3318 (work) or +852 9124 8324 (cell), or Steve Lin at steve.lin@kirkland.com, +86 10 5737 9315 (work) or +86 18610495593 (cell).
Thank you for your time and attention.
| Very truly yours, |
| /s/ David Zhang |
| David Zhang |
Enclosure
| c.c. | Jing Ju, Chief Executive Officer |
Dongning Wang, Chief Financial Officer
Michael Frederick Foust, Chairman of the Board
David Zhang, Esq., Partner, Kirkland & Ellis International LLP
Steve Lin, Esq., Partner, Kirkland & Ellis International LLP
King Li, Partner, Ernst & Young Hua Ming LLP
Julie Gao, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom LLP