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SEC Company Response from SHINECO, INC. (SISI) (CIK 0001300734) (SISI) — Sep 14, 2016

SHINECO, INC. (SISI) (CIK 0001300734)
Date: Sept. 14, 2016 · CIK: 0001300734 · Accession: 0001144204-16-123958

AI Filing Summary & Sentiment

File numbers found in text: 333-202803

Referenced dates: August 30, 2016

Date
September 14, 2016
Author
/s/ Yuying Zhang
Form
CORRESP
Company
SHINECO, INC. (SISI) (CIK 0001300734)

Letter

Division of Corporation Finance Re: Shineco, Inc. Comment Letter Dated August 30, 2016 regarding Post-effective Amendment to 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 30, 2016, we are writing to supply additional information and to indicate the changes that have been made in the enclosed Post-effective Amendment No. 4 to Form S-1 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 initial captioned Registration Statement for your review. Because we are not filing the Part I in this amendment, the redline shows only changes to the cover and Part II of the Amendment.

General

1. Please revise throughout the prospectus to avoid defining the term “promptly.” To this end please delete the phrase “within one business day” throughout.

As discussed with Commission Staff, the Registrant commits to implement this change in the final prospectus.

Susan Block, Attorney Advisor

September 14, 2016

Page 2

2. We note your response to our prior comments 1 and 10. If you will be selling the shares underlying the underwriter warrants pursuant to Rule 415(a)(1)(iii) please provide the undertakings required by Item 512(a) of Regulation S-K and check the box indicating this reliance on the registration statement cover page. If you will not be offering or selling the warrants pursuant to Rule 415 please tell us why this is the case.

We have revised the Amendment to check the box indicating reliance on Rule 415(a)(1)(iii) and have provided the undertakings required by Item 512(a) of Regulation S-K.

Thank you in advance for your assistance in reviewing this response and the Post-effective Amendment No. 4 to Form S-1.

Should you have any questions with respect to the above responses, please contact me.

Sincerely,
/s/ Yuying Zhang

Show Raw Text
CORRESP
1
filename1.htm

2nd
Floor, Wanyuan Business Center  s  10 N Hongda Road  s  Daxing District  s

Beijing
100176  s  People’s
Republic of China  s
(+86) 108722-7366

September 14, 2016

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 30, 2016
regarding

Post-effective Amendment to 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 30, 2016,
we are writing to supply additional information and to indicate the changes that have been made in the enclosed
Post-effective Amendment No. 4  to Form S-1 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 initial captioned Registration Statement for
your review. Because we are not filing the Part I in this amendment, the redline shows only changes to the cover and Part II
of the Amendment.

General

 1. Please revise throughout the prospectus to avoid defining the term “promptly.” To this end please delete the
phrase “within one business day” throughout.

As discussed with Commission Staff, the Registrant commits to
implement this change in the final prospectus.

Susan Block, Attorney Advisor

September 14, 2016

Page 2

 2. We note your response to our prior comments 1 and 10. If you will be selling the shares underlying the underwriter warrants
pursuant to Rule 415(a)(1)(iii) please provide the undertakings required by Item 512(a) of Regulation S-K and check the box indicating
this reliance on the registration statement cover page. If you will not be offering or selling the warrants pursuant to Rule 415
please tell us why this is the case.

We have revised the Amendment to check the box indicating
reliance on Rule 415(a)(1)(iii) and have provided the undertakings required by Item 512(a) of Regulation S-K.

Thank you in advance for your assistance
in reviewing this response and the Post-effective Amendment No. 4 to Form S-1.

Should you have any questions with respect
to the above responses, please contact me.

    Sincerely,

    /s/ Yuying Zhang

    Yuying Zhang