SEC Company Response from Recon Technology, Ltd (RCON) (CIK 0001442620) (RCON) — May 27, 2016
Recon Technology, Ltd (RCON) (CIK 0001442620)
Date: May 27, 2016 · CIK: 0001442620 · Accession: 0001144204-16-105599
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-34409
Referenced dates: May 19, 2016
Letter
VIA EDGAR Office of Information Technologies and Services RE: Recon Technology, Ltd. Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A Filed May 2, 2016 File No. 001-34409
Dear Ms. Nguyen:
On behalf of Recon Technology, Ltd. (the “Company”), we hereby respond to the letter dated May 19, 2016 (the “Letter”), from you to Liu Jia, Chief Financial Officer of the Company, setting forth the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in respect of the Company’s Preliminary Proxy Statement on Schedule 14A originally filed on February 16, 2016 and amended on May 2, 2016 (the “Proxy Statement”). A marked version of Amendment No. 2 to the Proxy Statement (the “Amended Proxy Statement”), reflecting all changes to the Proxy Statement, is being filed publicly with the Commission contemporaneously with the submission of this letter.
As discussed with the staff, the Company has determined that it will not be pursuing a business combination with QHHY, as referenced in the Proxy Statement, at this time and will instead proceed in holding its annual meeting solely for the election of its Class III directors and ratification of its auditor. The Company has updated the Amended Proxy Statement to remove all items related to Proposals 3 and 4, including all exhibits and financial statements related thereto. As such, the Company will not be addressing the Staff’s comments in the Letter at this time.
* * * * *
In addition to the foregoing, on behalf of the Company, we acknowledge that:
should the Commission or the Staff, acting pursuant to delegated authority, qualify the filing, it does not foreclose the Commission from taking any action with respect to the filing;
Loan Lauren P. Nguyen, Legal Branch Chief
U.S. Securities and Exchange Commission
May 27, 2016
Page 2 of 2
the action of the Commission or the Staff, acting pursuant to delegated authority, in qualifying the filing, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
the Company may not assert Staff comments and/or qualification as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We thank the Staff in advance for its consideration of the foregoing. Should you have any questions relating to the foregoing, please do not hesitate to contact me at any time at (212) 370-1300 (reception) or at my email address, swilliams@egsllp.com.
Very truly yours,
/s/ Sarah E. Williams
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CORRESP
1
filename1.htm
1345
AVENUE OF THE AMERICAS, 11TH FLOOR
NEW YORK, NEW YORK 10105
TELEPHONE: (212)
370-1300
FACSIMILE: (212) 370-7889
www.egsllp.com
VIA EDGAR
May 27, 2016
U.S. Securities and Exchange
Commission
Office of Information Technologies and
Services
100 F Street, N.E.
Mail Stop 4561
Washington, DC 20549
Attn: Loan Lauren P. Nguyen
RE: Recon Technology, Ltd.
Amendment
No. 1 to Preliminary Proxy Statement on Schedule 14A
Filed
May 2, 2016
File
No. 001-34409
Dear Ms. Nguyen:
On behalf of Recon Technology, Ltd. (the
“Company”), we hereby respond to the letter dated May 19, 2016 (the “Letter”), from you to
Liu Jia, Chief Financial Officer of the Company, setting forth the comments of the staff (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) in respect of the Company’s Preliminary Proxy Statement
on Schedule 14A originally filed on February 16, 2016 and amended on May 2, 2016 (the “Proxy Statement”). A
marked version of Amendment No. 2 to the Proxy Statement (the “Amended Proxy Statement”), reflecting all changes
to the Proxy Statement, is being filed publicly with the Commission contemporaneously with the submission of this letter.
As discussed with the staff, the Company
has determined that it will not be pursuing a business combination with QHHY, as referenced in the Proxy Statement, at this time
and will instead proceed in holding its annual meeting solely for the election of its Class III directors and ratification of its
auditor. The Company has updated the Amended Proxy Statement to remove all items related to Proposals 3 and 4, including all exhibits
and financial statements related thereto. As such, the Company will not be addressing the Staff’s comments in the Letter
at this time.
* * * * *
In addition to the foregoing, on behalf
of the Company, we acknowledge that:
should the Commission or the Staff, acting pursuant to delegated authority, qualify
the filing, it does not foreclose the Commission from taking any action with respect to the filing;
Loan
Lauren P. Nguyen, Legal Branch Chief
U.S. Securities and Exchange Commission
May 27, 2016
Page 2 of 2
the action of the Commission or the Staff, acting pursuant to delegated authority,
in qualifying the filing, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure
in the filing; and
the Company may not assert Staff comments and/or qualification as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the United States.
We thank the Staff in advance for its consideration
of the foregoing. Should you have any questions relating to the foregoing, please do not hesitate to contact me at any time at
(212) 370-1300 (reception) or at my email address, swilliams@egsllp.com.
Very truly yours,
/s/ Sarah E. Williams