SEC Comment Letter for ZK International Group Co., Ltd. (ZKIN) (CIK 0001687451) (ZKIN) — Apr 25, 2019

ZK International Group Co., Ltd. (ZKIN) (CIK 0001687451)
Date: April 25, 2019 · CIK: 0001687451 · Accession: 0000000000-19-007589

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File numbers found in text: 333-230860

Date

April 25, 2019

Author

Di Chen

Form

UPLOAD

Company

ZK International Group Co., Ltd. (ZKIN) (CIK 0001687451)

Letter

April 25, 2019 Di Chen Secretary ZK International Group Co., Ltd. No. 678 Dingxiang Road, Binhai Ind. Park Economic & Technology Development Zone Wenzhou, Zhejiang Province People's Republic of China 325025 Re:ZK International Group Co., Ltd. Registration Statement on Form F-3 Filed April 15, 2019 File No. 333-230860 Dear Mr. Chen: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Sherry Haywood, Staff Attorney at (202) 551-3345 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing and Construction

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April 25, 2019
Di Chen
Secretary
ZK International Group Co., Ltd.
No. 678 Dingxiang Road, Binhai Ind. Park
Economic & Technology Development Zone
Wenzhou, Zhejiang Province
People's Republic of China 325025
Re:ZK International Group Co., Ltd.
Registration Statement on Form F-3
Filed April 15, 2019
File No. 333-230860
Dear Mr. Chen:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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.
            Please contact Sherry Haywood, Staff Attorney at (202) 551-3345 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

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