SEC Comment Letter for Antelope Enterprise Holdings Ltd (AEHL) (CIK 0001470683) (AEHL) — Sep 18, 2015
Antelope Enterprise Holdings Ltd (AEHL) (CIK 0001470683)
Date: Sept. 18, 2015 · CIK: 0001470683 · Accession: 0000000000-15-046093
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-206516
Letter
Mail Stop 4631 September 17, 2015 Via E -mail Mr. Edmund Hen Chief Financial Officer China Ceramics Co., Ltd Junbing Industrial Zone, Anhai, Jinjiang City, Fujian Province, PRC
Re: China Ceramics Co., Ltd Amendment No. 1 to Registration Statement on Form 3 Filed September 15, 2015 File No. 333-206516
Dear Mr. Hen :
We have reviewed the above -captioned filing and have the following comments .
Exhibit 5.1
1. The opinion appears to qualify counsel’s expertise to the laws of the British Virgin Islands. Please note that an opinion of c ounsel with respect to a jurisdiction in which counsel is not admitted to practice is acceptable so long as the opinion is not qualified as to jurisdiction. Please file a new legality opinion (i) from counsel that is admitted to practice in the states of the laws governing the Indentures and warrant agreement or (ii) that does not include inappropriate qualifications pertaining to counsel’s expertise. See Section II.B.3.b. of Staff Legal Bulletin No.19.
Please contact Asia Timmons -Pierce, Staff Attorney , at (202) 551 -3754 or me at (202) 551- 3397 with any other questions.
Sincerely,
/s/ Jay Ingram
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Mail Stop 4631
September 17, 2015
Via E -mail
Mr. Edmund Hen
Chief Financial Officer
China Ceramics Co., Ltd
Junbing Industrial Zone, Anhai, Jinjiang City, Fujian Province, PRC
Re: China Ceramics Co., Ltd
Amendment No. 1 to Registration Statement on Form 3
Filed September 15, 2015
File No. 333-206516
Dear Mr. Hen :
We have reviewed the above -captioned filing and have the following comments .
Exhibit 5.1
1. The opinion appears to qualify counsel’s expertise to the laws of the British Virgin Islands.
Please note that an opinion of c ounsel with respect to a jurisdiction in which counsel is not
admitted to practice is acceptable so long as the opinion is not qualified as to jurisdiction.
Please file a new legality opinion (i) from counsel that is admitted to practice in the states of
the laws governing the Indentures and warrant agreement or (ii) that does not include
inappropriate qualifications pertaining to counsel’s expertise. See Section II.B.3.b. of Staff
Legal Bulletin No.19.
Please contact Asia Timmons -Pierce, Staff Attorney , at (202) 551 -3754 or me at (202)
551- 3397 with any other questions.
Sincerely,
/s/ Jay Ingram
Jay Ingram
Legal B ranch Chief
Office of Manufacturing and Construction
cc: Ralph V. De Martino (via e -mail)
Schiff Hardin LLP