Correspondence 0001493152-25-010209 from SHINECO, INC. (SISI) (CIK 0001300734) (SISI)
SHINECO, INC. (SISI) (CIK 0001300734)
Date: March 13, 2025 · CIK: 0001300734 · Accession: 0001493152-25-010209
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-285025
Referenced dates: March 5, 2025
Letter
Via EDGAR Division of Corporation Finance Office of Industrial Applications and Services Attention: Ms. Juan Grana Ms. Katherine Bagley Re: Shineco, Inc. Registration Statement on Form S-1 Filed February 18, 2025 File No. 333-285025
Dear Ms. Grana and Ms. Bagley:
This letter is in response to the letter dated March 5, 2025 from the staff (the "Staff") of the U.S. Securities and Exchange Commission (the "Commission") addressed to Shineco, Inc. (the "Company," "we," and "our"). For ease of reference, we have recited the Commission's comments in this response and numbered them accordingly. An amendment to the Registration Statement on Form S-1 ("Amendment No. 1") is being filed to accompany this letter.
Re g istration Statement on Form S-1
General
1. We note various references to the opinion of Shineco's PRC legal counsel, Beijing Yingke Law Firm, throughout the registration statement. For example, we note your disclosure on page 7 that "[i]n the opinion of [y]our PRC legal counsel, Beijing Yingke Law Firm, as this offering does not constitute a subsequent offering by [you], [you] are not required to file with the CSRC in accordance with the Trial Measures in connection with this offering", and your disclosure on page 25 that "[a]s confirmed by [y]our PRC counsel, Beijing Yingke Law Firm...[you] will not be subject to cybersecurity review by the CAC under the Cybersecurity Review Measures, nor will any such entity be subject to the Security Administration." Please revise to file the opinion of your PRC counsel.
Response : In response to the Staff's comment, we revised to file the opinion of our PRC legal counsel, Beijing Yingke Law Firm, as Exhibit 99.1 to Amendment No. 1.
In responding to the Staff's comments, the Company acknowledges that:
● the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
● the Staff's comments or changes to disclosure in response to the Staff's comments do not foreclose the Commission from taking any action with respect to the filing; and
● the Company may not assert the Staff's comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.
Very
truly yours,
/s/
Jennifer Zhan
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CORRESP
1
filename1.htm
Shineco,
Inc.
March
13, 2025
Via
EDGAR
U.S.
Securities and Exchange Commission
Division of Corporation Finance
Office
of Industrial Applications and Services
100 F Street, N.E.
Washington,
DC 20549
Attention:
Ms.
Juan Grana
Ms.
Katherine Bagley
Re:
Shineco,
Inc.
Registration Statement on Form S-1
Filed February 18, 2025
File
No. 333-285025
Dear
Ms. Grana and Ms. Bagley:
This
letter is in response to the letter dated March 5, 2025 from the staff (the "Staff") of the U.S. Securities and Exchange
Commission (the "Commission") addressed to Shineco, Inc. (the "Company," "we," and "our").
For ease of reference, we have recited the Commission's comments in this response and numbered them accordingly. An amendment to
the Registration Statement on Form S-1 ("Amendment No. 1") is being filed to accompany this letter.
Re g istration
Statement on Form S-1
General
1. We note various references to the opinion of Shineco's PRC legal counsel, Beijing Yingke Law Firm, throughout the registration statement. For example, we note your disclosure on page 7 that "[i]n the opinion of [y]our PRC legal counsel, Beijing Yingke Law Firm, as this offering does not constitute a subsequent offering by [you], [you] are not required to file with the CSRC in accordance with the Trial Measures in connection with this offering", and your disclosure on page 25 that "[a]s confirmed by [y]our PRC counsel, Beijing Yingke Law Firm...[you] will not be subject to cybersecurity review by the CAC under the Cybersecurity Review Measures, nor will any such entity be subject to the Security Administration." Please revise to file the opinion of your PRC counsel.
Response :
In response to the Staff's comment, we revised to file the opinion of our PRC legal counsel, Beijing Yingke Law Firm, as Exhibit
99.1 to Amendment No. 1.
In
responding to the Staff's comments, the Company acknowledges that:
●
the
Company is responsible for the adequacy and accuracy of the disclosure in the filing;
●
the
Staff's comments or changes to disclosure in response to the Staff's comments do not foreclose the Commission from taking
any action with respect to the filing; and
●
the
Company may not assert the Staff's comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
We
appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel,
Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.
Very
truly yours,
/s/
Jennifer Zhan
Jennifer
Zhan
Chief
Executive Officer
cc:
Ying
Li, Esq.
Hunter
Taubman Fischer & Li LLC