SEC Comment Letter for SHINECO, INC. (SISI) (CIK 0001300734) (SISI) — Aug 26, 2015
SHINECO, INC. (SISI) (CIK 0001300734)
Date: Aug. 26, 2015 · CIK: 0001300734 · Accession: 0000000000-15-043155
AI Filing Summary & Sentiment
Letter
Mailstop 3561 August 26 , 201 5 Yuying Zhang Chief Executive Officer Shineco, Inc. Room 3106, Building B #39 East 3rd Ring Middle Road Chaoyang District Beijing 100022 People’s Republic of China
Re: Shineco, Inc. Amendment No. 3 to Registration Statement on Form S -1 Filed August 18, 201 5 File No. 333 -202803
Dear Mr. Zhang :
We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the requested information . If you do not believe our comments apply to your facts and circumstanc es or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. Unless w e note otherwise, our references to prior comments are to comments in our August 14 , 2015 letter .
Placement, page 102
1. We note your revised disclosure in response to our prior comment 1 that Halcyon Cabot Partners “may be deemed” to be an underwriter . Please revise your disclosure to state that Halcyon Cabot Partners is an underwriter within the meaning of Section 2(a)(11) of the Securities Act.
Yuying Zhang Shineco, Inc. August 26, 2015 Page 2
You may contact Aamira Chaudhry at (202) 551 - 3389 or Lynwood Shenk at (202) 551 - 3380 if you have question s regarding comments on the financial statements and related matters. Please contact John Dana Brown at (202) 551 -3859 or me at (202) 551-3210 with any other questions.
Sincerely,
/s/ Susan Block
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Mailstop 3561
August 26 , 201 5
Yuying Zhang
Chief Executive Officer
Shineco, Inc.
Room 3106, Building B
#39 East 3rd Ring Middle Road
Chaoyang District
Beijing 100022
People’s Republic of China
Re: Shineco, Inc.
Amendment No. 3 to
Registration Statement on Form S -1
Filed August 18, 201 5
File No. 333 -202803
Dear Mr. Zhang :
We have reviewed your amended registration statement 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 this letter by amending your registration statement and
providing the requested information . If you do not believe our comments apply to your
facts and circumstanc es or do not believe an amendment is appropriate, please tell us why
in your response.
After reviewing any amendment to your registration statement and the
information you provide in response to these comments, we may have additional
comments. Unless w e note otherwise, our references to prior comments are to comments
in our August 14 , 2015 letter .
Placement, page 102
1. We note your revised disclosure in response to our prior comment 1 that Halcyon
Cabot Partners “may be deemed” to be an underwriter . Please revise your disclosure
to state that Halcyon Cabot Partners is an underwriter within the meaning of Section
2(a)(11) of the Securities Act.
Yuying Zhang
Shineco, Inc.
August 26, 2015
Page 2
You may contact Aamira Chaudhry at (202) 551 - 3389 or Lynwood Shenk at
(202) 551 - 3380 if you have question s regarding comments on the financial statements
and related matters. Please contact John Dana Brown at (202) 551 -3859 or me at (202)
551-3210 with any other questions.
Sincerely,
/s/ Susan Block
Susan Block
Attorney Advisor
Office of Transportation and Leisure
cc: Anthony W. Basch, Esq.
Kaufman & Canoles, P.C.