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: 0001144204-17-035306

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File numbers found in text: 333-218198

Date

June 30, 2017

Author

By: Boustead Securities, LLC

Form

CORRESP

Company

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

Letter

VIA EDGAR Division of Corporation Finance SECURITIES AND EXCHANGE COMMISSION Attention: Pamela Long Re: ZK International Group Co., Ltd.. Registration Statement on Form F-1 (File No. 333-218198)

Dear Ms. Long:

Acting on behalf of the several underwriters, we hereby join in the request of ZK International Group Co., Ltd.. that the effective date of the above-captioned Registration Statement be accelerated so that it will become effective at 5:30 p.m., Eastern Time, on June 30, 2017, or as soon thereafter as practicable.

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Securities Act"), each of the undersigned affirms that it is aware of its obligations under the Securities Act in connection with this offering.

Very Truly Yours,
By: Boustead Securities, LLC

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CORRESP
1
filename1.htm

Boustead Securities, LLC

6 Venture, Suite 325

Irvine, CA 92618

June 30, 2017

VIA EDGAR

Division of Corporation Finance

SECURITIES AND EXCHANGE COMMISSION

100 F Street, N.E.

Washington, DC 20549

Attention: Pamela Long

 Re: ZK
International Group Co., Ltd..

Registration
Statement on Form F-1

(File No. 333-218198)

Dear Ms. Long:

Acting on behalf of the several underwriters,
we hereby join in the request of ZK International Group Co., Ltd.. that the effective date of the above-captioned Registration
Statement be accelerated so that it will become effective at 5:30 p.m., Eastern Time, on June 30, 2017, or as soon thereafter as
practicable.

Pursuant to Rule 461 under the Securities
Act of 1933, as amended (the "Securities Act"), each of the undersigned affirms that it is aware of its obligations under
the Securities Act in connection with this offering.

        Very Truly Yours,

    By:  Boustead Securities, LLC

    By:
    /s/ Keith Moore

    Name:
    Keith Moore

    Title:
    Chief Executive Officer

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