SEC Comment Letter for SHINECO, INC. (SISI) (CIK 0001300734) (SISI) — Feb 23, 2016
SHINECO, INC. (SISI) (CIK 0001300734)
Date: Feb. 23, 2016 · CIK: 0001300734 · Accession: 0000000000-16-066049
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3561 February 23 , 201 6 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. 5 to Registration Statement on Form S -1 Filed January 27 , 201 6 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.
Yuying Zhang Shineco, Inc. February 23, 2016 Page 2
Related Party Transactions, page 81
Receivables from Related Parties, page 81
1. Please refer to the first paragraph in this section. We note the disclosure regarding a loan to your Chief Executive Officer and director. Please tell us how you intend to comply with Section 13(k) of the Exchange Act regarding the prohibition on personal loans to executives and directors.
You may contact Aamira Chaudhry at (202) 551 - 3389 or Lynwood Shenk at (202) 551 - 3380 if you have questions 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 February 23 , 201 6
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. 5 to
Registration Statement on Form S -1
Filed January 27 , 201 6
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.
Yuying Zhang
Shineco, Inc.
February 23, 2016
Page 2
Related Party Transactions, page 81
Receivables from Related Parties, page 81
1. Please refer to the first paragraph in this section. We note the disclosure
regarding a loan to your Chief Executive Officer and director. Please tell us how
you intend to comply with Section 13(k) of the Exchange Act regarding the
prohibition on personal loans to executives and directors.
You may contact Aamira Chaudhry at (202) 551 - 3389 or Lynwood Shenk at
(202) 551 - 3380 if you have questions 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.