SEC Comment Letter for SHINECO, INC. (SISI) (CIK 0001300734) (SISI) — Dec 11, 2017
SHINECO, INC. (SISI) (CIK 0001300734)
Date: Dec. 11, 2017 · CIK: 0001300734 · Accession: 0000000000-17-043020
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-221711
Letter
Mail Stop 3561 December 11, 201 7 Yuying Zhang Chief Executive Officer Shineco , Inc. Room 1001, Building T5, DaZu Square Daxing District, Beijing People’s Republic of China
Re: Shineco , Inc . Registration Statement on Form S-3 Filed November 21, 2017 File No. 333-221711
Dear Mr. Zhang :
We have limited our review of your registration statement to those issues we have addressed in our 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. Where 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 your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comm ents.
Exhibits
1. We note that you are registering debt securities under the registration statement. Please file the Form of Indenture, referenced in the Exhibit Index as Exhibit 4.1, in a pre - effective amendment to the registration statement. For furth er guidance, please refer to Trust Indenture Act Compliance and Disclosure Interpretations 201.02 and 201.04.
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.
Yuying Zhang Shineco , Inc. December 11, 201 7 Page 2
Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.
Please contact John Stickel at (202) 551 -3324 or me at (202) 551 -3217 with any questions.
Sincerely,
/s/ J. Nolan McWilliams
Show Raw Text
Mail Stop 3561 December 11, 201 7 Yuying Zhang Chief Executive Officer Shineco , Inc. Room 1001, Building T5, DaZu Square Daxing District, Beijing People’s Republic of China Re: Shineco , Inc . Registration Statement on Form S-3 Filed November 21, 2017 File No. 333-221711 Dear Mr. Zhang : We have limited our review of your registration statement to those issues we have addressed in our 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. Where 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 your response. After reviewing any amendment to your registration statement and the information you provide in response to these comments, we may have additional comm ents. Exhibits 1. We note that you are registering debt securities under the registration statement. Please file the Form of Indenture, referenced in the Exhibit Index as Exhibit 4.1, in a pre - effective amendment to the registration statement. For furth er guidance, please refer to Trust Indenture Act Compliance and Disclosure Interpretations 201.02 and 201.04. 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. Yuying Zhang Shineco , Inc. December 11, 201 7 Page 2 Refer to Rules 460 and 461 regarding requests for acceleration . Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact John Stickel at (202) 551 -3324 or me at (202) 551 -3217 with any questions. Sincerely, /s/ J. Nolan McWilliams J. Nolan McWilliams Attorney -Advisor Office of Transportation and Leisure