SEC Company Response from Antelope Enterprise Holdings Ltd (AEHL) (CIK 0001470683) (AEHL) — May 9, 2018
Antelope Enterprise Holdings Ltd (AEHL) (CIK 0001470683)
Date: May 9, 2018 · CIK: 0001470683 · Accession: 0001144204-18-026640
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-224302
Referenced dates: May 1, 2018
Letter
Division of Corporation Finance United States Securities and Exchange Commission Re: China Ceramics Co., Ltd. Registration Statement on Form F-3 Filed April 16, 2018 File No. 333-224302
Dear Mr. Chinos:
This letter sets forth the response of China Ceramics Co. Ltd. (the “Company”) to the comment letter dated May 1, 2018 of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) with respect to the Company’s Registration Statement on Form F-3 filed on April 16, 2018 (the “Registration Statement”). The Staff comment is reproduced below and followed by the Company’s response.
Form F-3 filed April 16, 2018
General
1. We note that your registration statement contains audited financial statements for the fiscal year ended December 31, 2016. Please be advised that we cannot accelerate the effective date of your registration statement until you have updated your financial statements in accordance with Item 8.A of Form 20-F. Please see Item 5(b)(2) of Form F-3.
Response: Please note the Company’s audited financial statements for the fiscal year ended December 31, 2017 were filed as a part of the Company’s Annual Report on Form 20-F filed with the SEC on May 4, 2018 (the “20-F”), and have been incorporated by referenced into the Registration Statement. The Company’s Pre-Effective Amendment No. 1 to the Registration Statement filed with the SEC on May 9, 2018 includes certain minor updates, including, without limitation, updated references to the December 31, 2017 audited financial statements. In addition, this amended filing also includes the Company’s independent auditors’ consent for incorporation by reference of their audits of the consolidated financial statements as of December 31, 2017 and 2016, respectively, which appears in the 20-F.
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May 9, 2018
Page 2
Please feel free to contact the undersigned at 202-724-6846 with any questions.
Very truly yours,
/s/ F. Alec Orudjev
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CORRESP
1
filename1.htm
Schiff
Hardin LLP
901
K Street NW
Suite
700
Washington,
DC 20001
T
202.778.6400
F
202.778.6460
schiffhardin.com
May 9, 2018
Alec F. Orudjev
(202) 724.6846
aorudjev@schiffhardin.com
VIA SEC EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attn: Jay Ingram, Legal Branch Chief
Sergio Chinos, Attorney-Advisor
Re: China Ceramics Co., Ltd.
Registration Statement on Form F-3
Filed April 16, 2018
File No. 333-224302
Dear Mr. Chinos:
This letter sets forth
the response of China Ceramics Co. Ltd. (the “Company”) to the comment letter dated May 1, 2018 of the staff of the
Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
with respect to the Company’s Registration Statement on Form F-3 filed on April 16, 2018 (the “Registration Statement”).
The Staff comment is reproduced below and followed by the Company’s response.
Form F-3 filed April 16, 2018
General
1. We note that your registration
statement contains audited financial statements for the fiscal year ended December 31, 2016. Please be advised that we cannot accelerate
the effective date of your registration statement until you have updated your financial statements in accordance with Item 8.A
of Form 20-F. Please see Item 5(b)(2) of Form F-3.
Response:
Please note the Company’s audited financial statements for the fiscal year ended
December 31, 2017 were filed as a part of the Company’s Annual Report on Form 20-F filed with the SEC on May 4, 2018
(the “20-F”), and have been incorporated by referenced into the Registration Statement. The
Company’s Pre-Effective Amendment No. 1 to the Registration Statement filed with the SEC on May 9, 2018 includes
certain minor updates, including, without limitation, updated references to the December 31, 2017 audited financial
statements. In addition, this amended filing also includes the Company’s independent auditors’ consent for
incorporation by reference of their audits of the consolidated financial statements as of December 31, 2017 and 2016,
respectively, which appears in the 20-F.
**************
May 9, 2018
Page 2
Please feel free to contact the undersigned
at 202-724-6846 with any questions.
Very truly yours,
/s/ F. Alec Orudjev
Cc: Hen Man Edmund, CFO
Ralph V. De Martino, Esq., Schiff Hardin
LLP