SEC Comment Letter for Scienture Holdings, Inc. (SCNX) (CIK 0001382574) (SCNX) — May 28, 2019
Scienture Holdings, Inc. (SCNX) (CIK 0001382574)
Date: May 28, 2019 · CIK: 0001382574 · Accession: 0000000000-19-008984
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-231246
Letter
May 28, 2019 Suren Ajjarapu Chief Executive Officer Trxade Group, Inc. 3840 Land O’ Lakes Boulevard Land O’ Lakes, Florida 34639 Re:Trxade Group, Inc. Registration Statement on Form S-1 Filed May 6, 2019 File No. 333-231246 Dear Mr. Ajjarapu: 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. If 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 comments. Registration Statement on Form S-1 Filed May 6, 2019 General 1.We note that you plan to incorporate by reference information pursuant to General Instruction VII of Form S-1. However, it appears that the company is a penny stock issuer as defined in Rule 3a51-1 of the Exchange Act and, therefore, is not eligible to use incorporation by reference. Please revise or advise. Please also update your financial disclosure for the quarterly period ended March 31, 2019. 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.
FirstName LastNameSuren Ajjarapu Comapany NameTrxade Group, Inc. May 28, 2019 Page 2 FirstName LastName Suren Ajjarapu Trxade Group, Inc. May 28, 2019 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 Ronald (Ron) Alper at 202-551-3329 or Brigitte Lippmann at 202-551- 3713 with any questions. Sincerely, Division of Corporation Finance Office of Beverages, Apparel and Mining cc: Blair Krueger, Esq.
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May 28, 2019
Suren Ajjarapu
Chief Executive Officer
Trxade Group, Inc.
3840 Land O’ Lakes Boulevard
Land O’ Lakes, Florida 34639
Re:Trxade Group, Inc.
Registration Statement on Form S-1
Filed May 6, 2019
File No. 333-231246
Dear Mr. Ajjarapu:
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. If 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 comments.
Registration Statement on Form S-1 Filed May 6, 2019
General
1.We note that you plan to incorporate by reference information pursuant to General
Instruction VII of Form S-1. However, it appears that the company is a penny stock issuer
as defined in Rule 3a51-1 of the Exchange Act and, therefore, is not eligible to use
incorporation by reference. Please revise or advise. Please also update your financial
disclosure for the quarterly period ended March 31, 2019.
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.
FirstName LastNameSuren Ajjarapu
Comapany NameTrxade Group, Inc.
May 28, 2019 Page 2
FirstName LastName
Suren Ajjarapu
Trxade Group, Inc.
May 28, 2019
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 Ronald (Ron) Alper at 202-551-3329 or Brigitte Lippmann at 202-551-
3713 with any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining
cc: Blair Krueger, Esq.