September 23, 2019
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attn: Ms. Barbara Jacobs
Borqs Technologies, Inc./Application For Withdrawal on Form RW for
Registration Statement on Form S-1 (File No. 333-223034)
Ladies and Gentlemen:
On February 14, 2018, Borqs Technologies, Inc., a Delaware
corporation (the “Company”), filed a registration statement (No. 333-223034) on Form S-1 (together with the exhibits
and amendments thereto, the “Registration Statement”) with the Securities and Exchange Commission (the “Commission”).
Pursuant to Rule 477 of the Securities Act of 1933 (the “Act”),
as amended, the Company hereby respectfully requests that the Commission consent to the withdrawal of the Registration Statement effective
as of the date hereof or as soon as practicable thereafter.
The Registration Statement has not been declared effective
and no securities covered by the Registration Statement have been issued or sold. The Company submits this request for withdrawal
of the Registration Statement as it has decided not to pursue the contemplated public offering at this time. Pursuant to Rule 477(b)
of the Act, the Company understands that this request for withdrawal of the Registration Statement will be deemed granted as of
the date hereof unless the Company receives notice from the Commission within 15 days of the date hereof that such request will
not be granted.
In accordance with Rule 457(p) of Regulation C, the Company
requests that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future
If you have any questions regarding the foregoing application
for withdrawal, please do not hesitate to contact myself at (86) 10-5975-6336 or Jessica Yuan of Ellenoff Grossman & Schole
LLP at (212) 370-1300.
Very truly yours,
/s/ Anthony K. Chan
Anthony K. Chan
Chief Financial Officer