Correspondence 0001493152-23-025026 from AiXin Life International, Inc. (AIXN) (CIK 0000835662) (AIXN)
AiXin Life International, Inc. (AIXN) (CIK 0000835662)
Date: July 20, 2023 · CIK: 0000835662 · Accession: 0001493152-23-025026
AI Filing Summary & Sentiment
File numbers found in text: 000-17284, 333-268190
Referenced dates: July 7, 2023
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CORRESP
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AiXin
Life International, Inc.
Hongxing
International Business Building 2, 14th FL, No. 69
Qingyun
South Ave., Jinjiang District
Chengdu
City, Sichuan Province, China
July
20, 2023
U.S.
Securities & Exchange Commission
Division
of Corporation Finance
Office
of Trade & Services
100
F Street, NE
Washington,
D.C. 20549
Attn:
Cara Wirth
Re:
AiXin Life International, Inc.
Form
10-K for Fiscal Year Ended December 31, 2022
Filed
May 1, 2023
File
No. 000-17284
Dear
Ms. Wirth:
Aixin
Life International, Inc. (the “Company,” “we,” “our” or “us”) acknowledges receipt of
the letter dated July 7, 2023, from the Office of Trade & Services with respect to its Report on Form 10-K for the year ended December
31, 2022.
For
your convenience, the two comments in the letter are set forth below along with the requested confirmations from the Company.
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that is no longer in effect.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.
The
Company confirms that it will not include in future filings made by the Company the statement referred to in the comment with respect
to the limitation on the incorporation by reference of the Management’s Report on Internal Control over Financial Reporting into
any other filings made by the Company.
General
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.
The
Company confirms that it will include in future Exchange Act filings all applicable China-related disclosures that it has included, or
will include, in its registration statement.
The
Company appreciates the reminder that it and its management are responsible for the accuracy and adequacy of the disclosures made in
its public filings, notwithstanding any review, comments, action or absence of action by the staff. Nevertheless, the Company thanks
the staff for its attentiveness and its review of its Form 10-K. If you have further comments, please feel free to contact to our counsel,
Vincent J. McGill at vmcgill@egsllp.com or by telephone at (516) 220-6569.
Sincerely,
/s/
Quanzhong Lin
Quanzhong
Lin, Chief Executive Officer
Cc:
Vincent J. McGill