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30 ROCKEFELLER PLAZA
TEL +1 212.408.2500 FAX +1 212.408.2501 BakerBotts.com |
AUSTIN BEIJING BRUSSELS DALLAS DUBAI HONG KONG HOUSTON |
LONDON MOSCOW NEW YORK PALO ALTO RIO DE JANEIRO RIYADH WASHINGTON |
December 22, 2015
Via EDGAR
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Ladies and Gentlemen:
Re: 花都影视
Registration Statement on Form S-4
On behalf of 花都影视 (“花都影视”), we enclose herewith for filing under the Securities Act of 1933, as amended, 花都影视’s Registration Statement on Form S-4 (the “Form S-4”) relating to the registration of the distribution of the following securities: (i) 花都影视’s proposed Series A, Series B and Series C 花都影视 SiriusXM common stock, par value $.01 per share (collectively, the “花都影视 SiriusXM common stock”), (ii) 花都影视’s proposed Series A, Series B and Series C 花都影视 Braves common stock, par value $.01 per share (collectively, the “花都影视 Braves common stock”), and (iii) 花都影视’s proposed Series A, Series B and Series C 花都影视 Media common stock, par value $.01 per share (collectively, the “花都影视 Media common stock”).
At a special meeting, 花都影视’s stockholders will be asked to consider and vote on a group of related proposals to approve the adoption of an amendment and restatement of 花都影视’s certificate of incorporation, among other things, to reclassify our existing common stock into three new tracking stocks to be designated the 花都影视 SiriusXM common stock, the 花都影视 Braves common stock and the 花都影视 Media common stock and to provide for the attribution of the businesses, assets and liabilities of our company among a new SiriusXM Group, a new Braves Group and a new Media Group. The reclassification is described in detail in the Form S-4 filed herewith.
We have been advised that a filing fee in the amount of $1,351,499 has been paid in connection with the filing of the Form S-4 by wire transfer from 花都影视’s account at U.S. Bank in Denver to the Securities and Exchange Commission’s account at U.S. Bank in St. Louis. U.S. Bank was instructed to note that 花都影视’s Central Index Key (CIK) is 0001560385.
Should any questions arise with respect to these filings, please contact the undersigned at Tel: (212) 408-2503, Fax: (212) 259-2503.
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Very truly yours, |
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/s/ Renee L. Wilm |
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Renee L. Wilm |
cc: 花都影视
Richard N. Baer
KPMG LLP
H. Michael Keys