Credit Suisse Securities (USA) LLC
Eleven Madison Avenue
New York, NY 10010
J.P. Morgan Securities LLC
383 Madison Avenue
New York, NY 10179
Citigroup Global Markets Inc.
388 Greenwich Street
New York, NY 10013
RBC Capital Markets, LLC
200 Vesey Street, 8th Floor
New York, NY 10281
China Renaissance Securities (Hong Kong) Limited
Units 8107-08, Level 81, International Commerce Centre
1 Austin Road West
Kowloon, Hong Kong
VIA EDGAR
October 28, 2016
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
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Attention: |
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Ms. Barbara C. Jacobs, Assistant Director |
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Mr. Gabriel Eckstein, Esq., Staff Attorney |
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Mr. Matthew Crispino, Esq., Staff Attorney |
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Ms. Kathleen Collins, Accounting Branch Chief |
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Ms. Melissa Kindelan, Staff Accountant |
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Re: |
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GDS Holdings Limited (the “Company”) |
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Registration Statement on Form F-1, as amended (Registration No. 333- 213951) |
Ladies and Gentlemen:
We hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness at 4:00 p.m., Eastern Time on November 1, 2016, or as soon thereafter as practicable.
Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended, we wish to advise you that, through the date hereof, 5,533 copies of the Company’s Preliminary Prospectus dated October 19, 2016 were distributed to prospective underwriters, institutional investors, dealers and others.
The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[signature page follows]
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Very truly yours, | |
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As representative of the several underwriters | |
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Credit Suisse Securities (USA) LLC | |
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By: |
/s/ Anthony Kontoleon |
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Name: Anthony Kontoleon |
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Title: Managing Director |
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[Signature Page to Acceleration Request (Underwriters)] | ||
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Very truly yours, | |
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As representative of the several underwriters | |
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J.P. Morgan Securities LLC | |
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By: |
/s/ Alice Takhtajan |
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Name: Alice Takhtajan |
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Title: Managing Director |
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[Signature Page to Acceleration Request (Underwriters)] | ||
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Very truly yours, | |
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As representative of the several underwriters | |
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Citigroup Global Markets Inc. | |
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By: |
/s/ Ho-Yin Lee |
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Name: Ho-Yin Lee |
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Title: Managing Director |
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[Signature Page to Acceleration Request (Underwriters)] | ||
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Very truly yours, | |
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As representative of the several underwriters | |
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RBC Capital Markets, LLC | |
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By: |
/s/ Madonna Park |
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Name: Madonna Park |
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Title: Managing Director |
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[Signature Page to Acceleration Request (Underwriters)] | ||
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Very truly yours, | |
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As representative of the several underwriters | |
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China Renaissance Securities (Hong Kong) Limited | |
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By: |
/s/ Jason Lam |
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Name: Jason Lam |
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Title: Head of IBD, President of China |
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[Signature Page to Acceleration Request (Underwriters)] | ||