SEC Comment Letter for SHINECO, INC. (SISI) (CIK 0001300734) (SISI) — Mar 30, 2016

SHINECO, INC. (SISI) (CIK 0001300734)
Date: March 30, 2016 · CIK: 0001300734 · Accession: 0000000000-16-070237

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Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

March 30, 2016

Author

/s/ John Dana Brown

Form

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Company

SHINECO, INC. (SISI) (CIK 0001300734)

Letter

Mailstop 3561 March 29 , 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. 6 to Registration Statement on Form S -1 Filed March 21 , 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 circumstances or do not believe an amendment is appropriate, please tell us why in yo ur 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 we note otherwise, our references to prior comments are to comments in our February 23, 2016 letter .

Exhibit 10.69

1. Please revise to file an executed copy of the agreement containing signatures or conformed signatures or advise.

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

Yuying Zhang Shineco, Inc. March 29, 2016 Page 2

and related matters. Please contact John Dana Brown at (202) 551 -3859 or me at (202) 551-3210 with any other questions.

Sincerely,
/s/ John Dana Brown

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Mailstop 3561           March 29 , 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. 6 to
Registration Statement on Form S -1
Filed March 21 , 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 circumstances or do not believe an amendment is appropriate, please tell us why
in yo ur 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 we note otherwise, our references to prior comments are to comments
in our February 23, 2016 letter .

Exhibit 10.69

1. Please  revise to file an executed copy of the agreement  containing signatures or
conformed signatures  or advise.

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

Yuying Zhang
Shineco, Inc.
March 29, 2016
Page 2

 and related matters.  Please contact John Dana Brown at (202) 551 -3859 or me at (202)
551-3210 with any other questions.

       Sincerely,

       /s/ John Dana Brown

for

Susan Block
Attorney Advisor
Office of Transportation and Leisure

cc: Anthony W. Basch, Esq.
Kaufman & Canoles, P.C.

SecProbe.io