SEC Company Response from ZK International Group Co., Ltd. (ZKIN) (CIK 0001687451) (ZKIN) — Jun 30, 2017
ZK International Group Co., Ltd. (ZKIN) (CIK 0001687451)
Date: June 30, 2017 · CIK: 0001687451 · Accession: 0001144204-17-035302
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-218198
Letter
ZK International Group Co., Ltd.
No. 678 Dingxiang Road, Binhai Industrial Park
Economic & Technology Development Zone
Wenzhou, Zheijiang Province
People’s Republic of China 325025
June 30, 2017
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re:
ZK International Group Co., Ltd. (the “Company)
Registration Statement on Form F-1
File No. 333-218198 (the “Registration Statement”)
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred to above be accelerated so that it will be declared effective at 5:30 pm on Friday, June 30, 2017, or as soon thereafter as is practicable. There have been no material adverse developments in the Company’s financial condition and/or results of operations since September 30, 2016.
The Company acknowledges that:
• should the Commission or the staff, acting pursuant to delegated authority, declares the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, 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 the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
ZK International Group Co., Ltd.
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ZK International Group Co., Ltd.
No. 678 Dingxiang Road, Binhai Industrial
Park
Economic & Technology Development
Zone
Wenzhou, Zheijiang Province
People’s Republic of China 325025
June 30, 2017
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re:
ZK International Group Co., Ltd. (the “Company)
Registration Statement on Form F-1
File No. 333-218198 (the “Registration Statement”)
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities
Act of 1933, as amended, the undersigned respectfully requests that the effective date for the Registration Statement referred
to above be accelerated so that it will be declared effective at 5:30 pm on Friday, June 30, 2017, or as soon thereafter as is
practicable. There have been no material adverse developments in the Company’s financial condition and/or results of operations
since September 30, 2016.
The Company acknowledges that:
•
should the Commission or the staff, acting pursuant to delegated authority, declares the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
•
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, 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 the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
ZK International Group Co., Ltd.
By:
/s/ Jiancong Huang
Name:
Jiancong Huang
Title:
Chairman of the Board & Chief Executive Officer