SEC Company Response from SHINECO, INC. (SISI) (CIK 0001300734) (SISI) — Aug 18, 2015
SHINECO, INC. (SISI) (CIK 0001300734)
Date: Aug. 18, 2015 · CIK: 0001300734 · Accession: 0001144204-15-050386
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-202803
Referenced dates: August 14, 2015
Letter
Division of Corporation Finance Re: Shineco, Inc. Comment Letter Dated August 14, 2015 regarding Registration Statement on Form S-1 File No. 333-202803
Dear Ms. Block:
On behalf of Shineco, Inc. (the “Registrant”) and in response to the comments set forth in your letter dated August 14, 2015, we are writing to supply additional information and to indicate the changes that have been made in the enclosed Amendment No. 3 to the captioned Registration Statement (the “Amendment”). Capitalized terms used herein shall have the meanings ascribed to them in the Amendment unless otherwise defined herein. We have also enclosed five redlined copies of the Amendment compared against the Registration Statement filed on August 7, 2014 for your review.
Placement, page 102
1. Please disclose that the placement agent Halcyon Cabot Partners is an underwriter within the meaning of Section 2(a)(11) of the Securities Act.
We have revised the Registration Statement to disclose that the placement agent, Halcyon Cabot Partners, may be deemed an underwriter within the meaning of Section 2(a)(11) of the Securities Act. The disclosure appears on page 102 and reads as follows:
The placement agent may be deemed to be an underwriter within the meaning of Section 2(a)(11) of the Securities Act and any commissions received by it and any profit realized on the sale of the securities by them while acting as principal might be deemed to be underwriting discounts or commissions under the Securities Act. The placement agent would be required to comply with the requirements of the Securities Act of 1933, as amended, or the Securities Act, and the Securities Exchange Act of 1934, as amended, or the Exchange Act.
Ms. Susan Block, Assistant Director
August 18, 2015
Page 2
Thank you in advance for your assistance in reviewing this response and the Third Amendment to the Registration Statement on Form S-1.
Should you have any questions with respect to the above responses, please contact me.
Sincerely,
/s/ Yuying Zhang
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Room
3106, Building B s
#39 East 3rd Ring Middle Road s
Chaoyang District s
Beijing
100022 s People’s
Republic of China s
(+86) 105869-3011
August 18, 2015
Ms. Susan Block, Attorney Advisor
Division of Corporation Finance
U.S. Securities and Exchange Commission
Mail Stop 3561
100 F Street, N.E.
Washington, D.C. 20549-4631
Re: Shineco, Inc.
Comment Letter Dated August 14, 2015
regarding
Registration Statement on Form S-1
File No. 333-202803
Dear Ms. Block:
On behalf of Shineco, Inc. (the “Registrant”) and
in response to the comments set forth in your letter dated August 14, 2015, we are writing to supply additional information and
to indicate the changes that have been made in the enclosed Amendment No. 3 to the captioned Registration Statement (the “Amendment”).
Capitalized terms used herein shall have the meanings ascribed to them in the Amendment unless otherwise defined herein. We have
also enclosed five redlined copies of the Amendment compared against the Registration Statement filed on August 7, 2014 for your
review.
Placement, page 102
1.
Please disclose that the placement agent Halcyon Cabot Partners is an underwriter within the meaning of Section 2(a)(11) of the Securities Act.
We have revised the Registration Statement to disclose
that the placement agent, Halcyon Cabot Partners, may be deemed an underwriter within the meaning of Section 2(a)(11) of the Securities
Act. The disclosure appears on page 102 and reads as follows:
The placement agent may be deemed to be
an underwriter within the meaning of Section 2(a)(11) of the Securities Act and any commissions received by it and any profit realized
on the sale of the securities by them while acting as principal might be deemed to be underwriting discounts or commissions under
the Securities Act. The placement agent would be required to comply with the requirements of the Securities Act of 1933, as amended,
or the Securities Act, and the Securities Exchange Act of 1934, as amended, or the Exchange Act.
Ms. Susan Block, Assistant Director
August 18, 2015
Page 2
Thank you in advance for your assistance
in reviewing this response and the Third Amendment to the Registration Statement on Form S-1.
Should you have any questions with respect to the above responses,
please contact me.
Sincerely,
/s/ Yuying Zhang
Yuying Zhang
Chief Executive Officer