SEC Comment Letter for Dogness (International) Corp (DOGZ) (CIK 0001707303) (DOGZ) — Aug 14, 2017
Dogness (International) Corp (DOGZ) (CIK 0001707303)
Date: Aug. 14, 2017 · CIK: 0001707303 · Accession: 0000000000-17-028681
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 4631 August 14, 2017 Silong Chen Chief Executive Officer Dogness (International) Corporation Tongsha Industrial Estate, East District Dongguan, Guangdong People’s Republic of China 523217
Re: Dogness (International) Corporation Amendment No. 1 to Draft Registration Statement on Form F -1 Submitted August 2, 2017 CIK No. 1707303
Dear Mr. Chen :
We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments.
General
1. Please provide updated financial statements and related di sclosures to the extent required by Item 8.A.4 and the related instructions of Form 20 -F.
Operating and Financial Review and Prospects, page 45
2. We have reviewed your response to prior comment nine and note the additional disclosure added on page 124. As we previously requested, please also enhance your discussion of results of operations to quantify and discuss the impact of foreign currency translation on revenues and expenses during each period presented.
Silong Chen Dogness (International) Corporation August 14, 2017 Page 2
3. We have reviewed your response to prior commen t 10 and note the additional disclosure added on page 11. As we previously requested, please also enhance your discussion of results of operations to more fully address the reasons for the declines in the quant ity of product s sold of 24.3% during the six months ended December 31, 2016 and 9.3% during the year ended June 30, 2016. To the extent applicable, please address any material changes in the quantity of product s sold subsequent to December 31, 2016.
You may contact Jeff Gordon, Staff Accountant, at (202) 551 -3866 or Anne McConnell, Staff Accountant, at (202) 551 -3709 if you have questions regarding comments on the financial statements and related matters. Please contact Sergio Chinos, Staff Attorney , at (202) 551 -7844 or Jay Ingram, Legal Branch Chief, at (202) 551 -3397 with any other questions.
Sincerely,
/s/ Pamela A. Long
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Mail Stop 4631 August 14, 2017 Silong Chen Chief Executive Officer Dogness (International) Corporation Tongsha Industrial Estate, East District Dongguan, Guangdong People’s Republic of China 523217 Re: Dogness (International) Corporation Amendment No. 1 to Draft Registration Statement on Form F -1 Submitted August 2, 2017 CIK No. 1707303 Dear Mr. Chen : We have reviewed your amended draft 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 providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. General 1. Please provide updated financial statements and related di sclosures to the extent required by Item 8.A.4 and the related instructions of Form 20 -F. Operating and Financial Review and Prospects, page 45 2. We have reviewed your response to prior comment nine and note the additional disclosure added on page 124. As we previously requested, please also enhance your discussion of results of operations to quantify and discuss the impact of foreign currency translation on revenues and expenses during each period presented. Silong Chen Dogness (International) Corporation August 14, 2017 Page 2 3. We have reviewed your response to prior commen t 10 and note the additional disclosure added on page 11. As we previously requested, please also enhance your discussion of results of operations to more fully address the reasons for the declines in the quant ity of product s sold of 24.3% during the six months ended December 31, 2016 and 9.3% during the year ended June 30, 2016. To the extent applicable, please address any material changes in the quantity of product s sold subsequent to December 31, 2016. You may contact Jeff Gordon, Staff Accountant, at (202) 551 -3866 or Anne McConnell, Staff Accountant, at (202) 551 -3709 if you have questions regarding comments on the financial statements and related matters. Please contact Sergio Chinos, Staff Attorney , at (202) 551 -7844 or Jay Ingram, Legal Branch Chief, at (202) 551 -3397 with any other questions. Sincerely, /s/ Pamela A. Long Pamela A. Long Assistant Director Office of Manufacturing and Construction cc: Anthony W. Basch, Esq. Yunhao Chen