SEC Company Response from SHINECO, INC. (SISI) (CIK 0001300734) (SISI) — Aug 27, 2015
SHINECO, INC. (SISI) (CIK 0001300734)
Date: Aug. 27, 2015 · CIK: 0001300734 · Accession: 0001144204-15-052239
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-202803
Referenced dates: August 26, 2015
Letter
Division of Corporation Finance Re: Shineco, Inc. Comment Letter Dated August 26, 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 26, 2015, we are writing to supply additional information and to indicate the changes that have been made in the enclosed Amendment No. 4 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 18, 2014 for your review.
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.
We have revised the Registration Statement to disclose that the placement agent, Halcyon Cabot Partners, is an underwriter within the meaning of Section 2(a)(11) of the Securities Act. The disclosure appears on page 102 and reads as follows:
Ms. Susan Block, Assistant Director
August 27, 2015
Page 2
The placement agent is 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 it while acting as principal are underwriting discounts or commissions under the Securities Act. As an underwriter, the placement agent is 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.
Thank you in advance for your assistance in reviewing this response and the Fourth 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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CORRESP
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filename1.htm
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 27, 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 26, 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 26, 2015, we are writing to supply additional information and
to indicate the changes that have been made in the enclosed Amendment No. 4 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 18, 2014 for your
review.
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.
We have revised the Registration Statement to disclose
that the placement agent, Halcyon Cabot Partners, is an underwriter within the meaning of Section 2(a)(11) of the Securities Act.
The disclosure appears on page 102 and reads as follows:
Ms. Susan Block, Assistant
Director
August 27, 2015
Page 2
The placement agent is 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 it while acting as principal are underwriting discounts or commissions under the Securities Act. As an
underwriter, the placement agent is 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.
Thank you in advance for your assistance
in reviewing this response and the Fourth 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