Simpson Thacher & Bartlett
ICBC TOWER, 35TH FLOOR
3 GARDEN ROAD, CENTRAL
HONG KONG
TELEPHONE: +852-2514-7600
FACSIMILE: +852-2869-7694
| Direct Dial Number | E-mail Address |
| +852-2514-7660 | dfertig@stblaw.com |
July 20, 2023
VIA EDGAR
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Attention: | Mr. Dan Morris | |
| Ms. Jennifer Thompson | ||
| Ms. Kathleen Collins | ||
| Ms. Megan Akst |
| Re: | GDS Holdings Limited | |
| Form 20-F for the Fiscal Year Ended December 31, 2022 | ||
| Filed April 4, 2023 | ||
| File No. 001-37925 |
Dear Division:
On behalf of our client, GDS Holdings Limited (the “Company”), we are submitting this letter in response to your correspondence dated June 27, 2023 (the “June 27 Letter”) concerning the above-referenced annual report on Form 20-F that the Company filed with the Commission.
In the June 27 Letter, you requested that the Company respond to the Staff’s comments within 10 business days or advise the Staff when the Company will respond. The Company respectfully requests that the Company be given an until August 3, 2023 (the tenth business day from the date hereof) and expects to respond no later than that date.
michael j.c.M. ceulen marjory j. ding daniel fertig adam C. furber YI GAO MAKIKO HARUNARI Ian C. Ho JONATHAN HWANG anthony d. king jin hYUK park ERIK P. WANG christopher k.s. wong
resident partners
simpson thacher & bartlett, hong kong is an affiliate of simpson thacher & bartlett llp with offices in:
New York Beijing Brussels Houston LONDON Los Angeles Palo Alto SÃO PAULO TOKYO Washington,D.C.
| Simpson Thacher & Bartlett | ||
 | ||
| Division of Corporation Finance | ||
| July 20, 2023 | -2- | U.S. Securities and Exchange Commission |
The Company further respectfully requests that the Staff also address future correspondence to Mr. Dan Newman, the Company’s CFO (Dan.newman@gds-services.com) and Ms. Jamie Khoo, the Company’s COO (jamie@gds-services.com).
* * *
In the meantime, please do not hesitate to contact me at +852-2514-7660 (work) or dfertig@stblaw.com (email).
| Very truly yours, | |
| /s/ Daniel Fertig | |
| Daniel Fertig |
| cc: | William Wei Huang, Chief Executive Officer Daniel Newman, Chief Financial Officer |
Jamie Khoo, Chief Operating Officer
Andy Wenfeng Li, General Counsel and Company Secretary
GDS Holdings Limited