March 22, 2021
CONFIDENTIAL SUBMISSION
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Stevanato Group S.p.A. |
Confidential Submission of Draft Registration Statement on Form F-1
Ladies and Gentlemen:
On behalf of Stevanato Group S.p.A., an Italian joint stock company incorporated under the laws of the Republic of Italy (società per azioni) (the “Company”), we hereby confidentially submit pursuant to Section 6(e) of the Securities Act of 1933, as amended, a Draft Registration Statement on Form F-1 (the “Registration Statement”) for confidential non-public review by the Staff of the U.S. Securities and Exchange Commission prior to the public filing of the Registration Statement.
The Company qualifies as an “Emerging Growth Company”, as defined in Rule 12b-2 under the Securities Exchange Act of 1934, as amended. Pursuant to Section 71003 of the Fixing America’s Surface Transportation (FAST) Act and based on guidance issued by the SEC in connection therewith – specifically Securities Act Forms – Question 101.04 of the SEC’s Compliance and Disclosure Interpretations issued on August 17, 2017 – the Company is omitting from the Registration Statement its annual financial statements as of and for the year ended December 31, 2018, because it reasonably believes that such financial statements will not be required to be included in the Registration Statement at the time of the contemplated offering.