SEC Comment Letter for Antiaging Quantum Living (AAQL) — Jun 2, 2017
Antiaging Quantum Living Inc.
Date: June 2, 2017 · CIK: 0001672571 · Accession: 0000000000-17-019402
AI Filing Summary & Sentiment
File numbers found in text: 333-211051
Letter
Mail Stop 3233 June 2 , 2017 Via E -mail Wanjun Xie Chief Executive Officer Achison Inc. 3906 Main Street , Suite 207 Flushing, NY 11354
Re: Achison, Inc. Amendment No. 10 to Registration Statement on Form S -1 Filed May 18, 2017 File No. 333-211051
Dear Mr. Xie:
We have reviewed your amended registration statement and have the following 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 amendm ent 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. Unless we note otherwise , our references to prior comments are to comments in our May 15, 2017 letter .
General
1. Please confirm that you reasonably expect to offer and sell the registered $99.9 billion shares of common stock in the next two years . Refer to Rule 415(a)(2).
2. Please revis e to update the financial statements through the fiscal quarter ended March 31, 2017 in accordance to Rule 8 -08 of Regulation S -X.
Exhibit 23
3. Please include updated consents from your independent accountants in your next pre - effective amendment. Please be advised that the consents for the inclusion of the reports from your independent accountants in the registration statement prior to effectiveness should not be older than 30 days.
Wanjun Xie Achison Inc. June 2, 2017 Page 2
You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilso n Lee, Staff Accountant, at (202) 551 -3468 if you have questions regarding comments on the financ ial statements and related matters. Please contact Stacie Gorman at (202) 551 -3585 or me at (202) 551-3673 with any other questions.
Sincerely,
/s/ Folake Ayoola
Show Raw Text
Mail Stop 3233
June 2 , 2017
Via E -mail
Wanjun Xie
Chief Executive Officer
Achison Inc.
3906 Main Street , Suite 207
Flushing, NY 11354
Re: Achison, Inc.
Amendment No. 10 to Registration Statement on Form S -1
Filed May 18, 2017
File No. 333-211051
Dear Mr. Xie:
We have reviewed your amended registration statement and have the following
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 amendm ent 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. Unless we note
otherwise , our references to prior comments are to comments in our May 15, 2017 letter .
General
1. Please confirm that you reasonably expect to offer and sell the registered $99.9 billion
shares of common stock in the next two years . Refer to Rule 415(a)(2).
2. Please revis e to update the financial statements through the fiscal quarter ended March
31, 2017 in accordance to Rule 8 -08 of Regulation S -X.
Exhibit 23
3. Please include updated consents from your independent accountants in your next pre -
effective amendment. Please be advised that the consents for the inclusion of the reports
from your independent accountants in the registration statement prior to effectiveness
should not be older than 30 days.
Wanjun Xie
Achison Inc.
June 2, 2017
Page 2
You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilso n Lee, Staff
Accountant, at (202) 551 -3468 if you have questions regarding comments on the financ ial
statements and related matters. Please contact Stacie Gorman at (202) 551 -3585 or me at (202)
551-3673 with any other questions.
Sincerely,
/s/ Folake Ayoola
Folake Ayoola
Senior Counsel
Office of Real Estate and
Commodities