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Correspondence 0001493152-25-002617 from Bon Natural Life Ltd (BON)

Bon Natural Life Ltd
Date: Jan. 16, 2025 · CIK: 0001816815 · Accession: 0001493152-25-002617

AI Filing Summary & Sentiment

File numbers found in text: 333-283333

Referenced dates: November 26, 2024

Date
Jan. 16, 2025
Author
THE
Form
CORRESP
Company
Bon Natural Life Ltd

Letter

Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences Re: Bon Natural Life Amendment No. 1 to Registration Statement on Form F-1 Submitted November 19, 2024 File No. 333-283333

Dear Sir and Madam:

On behalf of Bon Natural Life, a Cayman Islands exempted company (the “Company”), we hereby file with the Securities and Exchange Commission (the “Commission”) an amended registration statement on Form F-1 (the “Amended Registration Statement”) in response to the comments of the staff (the “Staff”), dated November 26, 2024, with reference to the Company’s Registration Statement on Form F-1 filed with the Commission on November 19, 2024.

For the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Registration Statement on Form F-1

Cover Page

1. Please revise your cover page heading to quantify the number of Ordinary Shares you are registering. Refer to item 501(b)(2) of Regulation S-K.

Response: The Amended Registration Statement has been revised in accordance with the comments of the Staff on the cover page.

420 Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686

2. We note your disclosure on page 7 that “ordinary shares started to trade on the Nasdaq Capital Market under the ticker symbol “BON” since June 24, 2021.” Please revise your cover page to disclose the markets for your securities. Refer to Item 501(b)(4) of Regulation S-K.

Response: The Amended Registration Statement has been revised in accordance with the comments of the Staff on the cover page.

Management

Compensation, page 95

3. Please revise to disclose the compensation of your executive officers and directors for your most recently completed financial year. Refer to Item 6.B of Form 20-F.

Response: The Amended Registration Statement has been revised in accordance with the comments of the Staff on the page 98.

We hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do not hesitate to contact the undersigned.

Sincerely,
THE
CRONE LAW GROUP, P.C.

Show Raw Text
CORRESP
1
filename1.htm

    Mark
                                            E. Crone

    Managing
    Partner

    mcrone@cronelawgroup.com

January
16, 2025

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Life Sciences

100
F Street, N.E.

Washington,
DC 20549

Attn:
Daniel Crawford

Joe
McCann

John
Coleman

    Re:
    Bon
    Natural Life

    Amendment
    No. 1 to Registration Statement on Form F-1

    Submitted
    November 19, 2024

    File
    No. 333-283333

Dear
Sir and Madam:

On
behalf of Bon Natural Life, a Cayman Islands exempted company (the “Company”), we hereby file with the Securities and Exchange
Commission (the “Commission”) an amended registration statement on Form F-1 (the “Amended Registration Statement”)
in response to the comments of the staff (the “Staff”), dated November 26, 2024, with reference to the Company’s Registration
Statement on Form F-1 filed with the Commission on November 19, 2024.

For
the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company.
Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to
the Company on a consolidated basis.

Registration
Statement on Form F-1

Cover
Page

    1.
    Please
    revise your cover page heading to quantify the number of Ordinary Shares you are registering. Refer to item 501(b)(2) of Regulation
    S-K.

Response:
The Amended Registration Statement has been revised in accordance with the comments of the Staff on the cover page.

420 Lexington Avenue, Suite 2446, New York,
NY 10170 | 646-861-7891

12121 Wilshire Blvd., Suite 810, Los Angeles,
CA 90025 | 818-930-5686

    2.
    We
    note your disclosure on page 7 that “ordinary shares started to trade on the Nasdaq Capital Market under the ticker symbol
    “BON” since June 24, 2021.” Please revise your cover page to disclose the markets for your securities. Refer to
    Item 501(b)(4) of Regulation S-K.

Response:
The Amended Registration Statement has been revised in accordance with the comments of the Staff on the cover page.

Management

Compensation,
page 95

    3.
    Please
    revise to disclose the compensation of your executive officers and directors for your most recently completed financial year. Refer
    to Item 6.B of Form 20-F.

Response:
The Amended Registration Statement has been revised in accordance with the comments of the Staff on the page 98.

We
hope the Amended Registration Statement addresses the comments of the Commission. If we can provide any further assistance, please do
not hesitate to contact the undersigned.

  Sincerely,

  THE
  CRONE LAW GROUP, P.C.

  /s/ Joe Laxague

  Joe Laxague, Esq.

cc:
Yongwei Hui

420 Lexington Avenue, Suite 2446, New York, NY 10170 | 646-861-7891

12121 Wilshire Blvd., Suite 810, Los Angeles, CA 90025 | 818-930-5686