Response of the Office of Mergers and Acquisition
Division of Corporation Finance

June 7, 2023

Via Email

George A. Stephanakis
Cravath, Swaine & Moore LLP
GStephanakis@cravath.com

Re:    Rothschild & Co Concordia SAS
          Request for Exemptive Relief from Rule 14e-5 under the Securities Exchange Act of                1934

Dear Mr. Stephanakis:

We are responding to your letter dated June 7, 2023, addressed to Ted Yu and Perry Hindin. To avoid having to recite or summarize the facts set forth in your letter, we attach copies of your correspondence and the accompanying letter from French counsel. Unless otherwise noted, capitalized terms in this letter have the same meaning as in your letter dated June 7, 2023.

Based on the representations and facts presented in your letter, the Division of Corporation Finance, acting for the Commission pursuant to delegated authority, by separate order is granting an exemption from Exchange Act Rule 14e-5, under the circumstances described in your letter.

The exemptive relief provided is based on the representations made to the Division in your request. Any different facts or conditions may require the Division to reach a different conclusion. Further, this response does not express any legal conclusion on the questions presented or any views on any other questions that the transaction may raise.