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SEC Company Response from ATIF Holdings Ltd (ZBAI) (CIK 0001755058) (AUC) — Feb 6, 2019

ATIF Holdings Ltd (ZBAI) (CIK 0001755058)
Date: Feb. 6, 2019 · CIK: 0001755058 · Accession: 0001144204-19-005350

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File numbers found in text: 333-228750

Date
February 6, 2019
Author
Boustead Securities, LLC
Form
CORRESP
Company
ATIF Holdings Ltd (ZBAI) (CIK 0001755058)

Letter

Boustead Securities, LLC

6 Venture, Suite

Irvine, CA 92618 USA

February 6, 2019

VIA EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: Asia Times Holdings Limited

Registration Statement on Form F-1 (File No. 333-228750)

To Whom It May Concern:

In connection with the above-referenced Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby join in the request of Asia Times Holdings Limited that the effective date of the Registration Statement be accelerated so that it will be declared effective at 4:00 p.m. (EDT), February 8, 2019 or as soon thereafter as practicable.

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

Very truly yours,
Boustead Securities, LLC

Show Raw Text
CORRESP
1
filename1.htm

Boustead Securities,
LLC

6 Venture, Suite
265

Irvine, CA 92618
USA

February 6, 2019

VIA EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:
    Asia Times Holdings Limited

    Registration Statement on Form F-1 (File No. 333-228750)

To Whom It May Concern:

In connection with the above-referenced
Registration Statement, and pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby join in the request of
Asia Times Holdings Limited that the effective date of the Registration Statement be accelerated so that it will be declared effective
at 4:00 p.m. (EDT), February 8, 2019 or as soon thereafter as practicable.

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

Very truly yours,

Boustead Securities, LLC

    By:
    /s/ Keith Moore

    Name:
    Keith Moore

    Title:
    Chief Executive Officer