SEC Comment Letter 0000000000-23-007253 to AiXin Life International, Inc. (AIXN) (CIK 0000835662) (AIXN)
AiXin Life International, Inc. (AIXN) (CIK 0000835662)
Date: July 7, 2023 · CIK: 0000835662 · Accession: 0000000000-23-007253
AI Filing Summary & Sentiment
File numbers found in text: 000-17284, 333-268190
Letter
United States securities and exchange commission logo July 7, 2023 Quanzhong Lin Chief Executive Officer, President, and Secretary AiXin Life International, Inc. Hongxing International Business Building 2, 14th FL, No. 69 Qingyun South Ave., Jinjiang District Chengdu City, Sichuan Province, China Re:AiXin Life International, Inc. Form 10-K for Fiscal Year Ended December 31, 2022 Filed May 1, 2023 File No. 000-17284 Dear Quanzhong Lin: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2022 Management's Annual Report on Internal Control over Financial Reporting, page 35 1.We note your statement that management’s report on internal control over financial reporting “shall not be deemed to be filed for purposes of Section 18 of the Securities Exchange Act of 1934, or otherwise subject to the liabilities of that section, and is not incorporated by reference into any filing of the Company, whether made before or after the date hereof, regardless of any general incorporation language in such filing.” This statement appears to have been made in reliance on Item 308T of Regulation S-K, a special temporary provision that is no longer in effect. Refer to SEC Release No. 33- 9142, including footnote 15. Please confirm that the company will not include the statement in future filings, or advise why the current language is appropriate. General
FirstName LastNameQuanzhong Lin Comapany NameAiXin Life International, Inc. July 7, 2023 Page 2 FirstName LastName Quanzhong Lin AiXin Life International, Inc. July 7, 2023 Page 2 2.We note that your registration statement on Form S-1 (File No. 333-268190) is currently under review, and we have issued a number of comments on your China-related disclosures. Please confirm to us in writing that you will include in future Exchange Act filings all applicable China-related disclosures that you have included, or will include, in your registration statement. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Patrick Kuhn at (202) 551-3308 or Abe Friedman at (202) 551-8298 if you have questions regarding comments on the financial statements and related matters. Please contact Cara Wirth at (202) 551-7127 or Dietrich King at (202) 551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services
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United States securities and exchange commission logo
July 7, 2023
Quanzhong Lin
Chief Executive Officer, President, and Secretary
AiXin Life International, Inc.
Hongxing International Business Building 2, 14th FL, No. 69
Qingyun South Ave., Jinjiang District
Chengdu City, Sichuan Province, China
Re:AiXin Life International, Inc.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed May 1, 2023
File No. 000-17284
Dear Quanzhong Lin:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
Management's Annual Report on Internal Control over Financial Reporting, page 35
1.We note your statement that management’s report on internal control over financial
reporting “shall not be deemed to be filed for purposes of Section 18 of the Securities
Exchange Act of 1934, or otherwise subject to the liabilities of that section, and is not
incorporated by reference into any filing of the Company, whether made before or after
the date hereof, regardless of any general incorporation language in such filing.” This
statement appears to have been made in reliance on Item 308T of Regulation S-K, a
special temporary provision that is no longer in effect. Refer to SEC Release No. 33-
9142, including footnote 15. Please confirm that the company will not include the
statement in future filings, or advise why the current language is appropriate.
General
FirstName LastNameQuanzhong Lin
Comapany NameAiXin Life International, Inc.
July 7, 2023 Page 2
FirstName LastName
Quanzhong Lin
AiXin Life International, Inc.
July 7, 2023
Page 2
2.We note that your registration statement on Form S-1 (File No. 333-268190) is currently
under review, and we have issued a number of comments on your China-related
disclosures. Please confirm to us in writing that you will include in future Exchange Act
filings all applicable China-related disclosures that you have included, or will include, in
your registration statement.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
You may contact Patrick Kuhn at (202) 551-3308 or Abe Friedman at (202) 551-8298 if
you have questions regarding comments on the financial statements and related matters. Please
contact Cara Wirth at (202) 551-7127 or Dietrich King at (202) 551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services