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United States securities and exchange commission logo
February 2, 2023
Joey Wat
Chief Executive Officer
Yum China Holdings, Inc.
7100 Corporate Drive
Plano, Texas 75024
Re: Yum China Holdings,
Inc.
Form 10-K for the
Year Ended December 31, 2021
Correspondence
Filed January 3, 2023
File No. 1-37762
Dear Joey Wat:
We have reviewed your January 3, 2023 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to this comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this comment, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
December 16, 2022 letter.
Correspondence Filed January 3, 2023
Item 1A. Risk Factors, page 9
1. We note your response
to comment 10. Revise to state whether you believe that you are
compliant with the
regulations or policies that have been issued by the CAC to date,
notwithstanding the
various uncertainties you disclose. In this regard, we are not aware of
any regulatory process
in which you are expected to be identified as a "critical information
infrastructure
operator" before ensuring compliance with the Revised Cybersecurity
Review Measures.
Joey Wat
FirstName
Yum ChinaLastNameJoey
Holdings, Inc. Wat
Comapany2,NameYum
February 2023 China Holdings, Inc.
February
Page 2 2, 2023 Page 2
FirstName LastName
Please contact Taylor Beech at 202-551-4515 or Mara Ransom at
202-551-3264 with any
questions.
Sincerely,
Division of Corporation
Finance
Office of Trade &
Services
cc: Lindsey Smith, Esq.