July 2, 2007 | |
Thomas J. Poletti 310.552.5045 Fax: 310.552.5001 thomas.poletti@klgates.com |
VIA FEDERAL EXPRESS
Mr. H. Christopher Owings
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Re: Fuqi International, Inc.
Dear Mr. Owings:
On behalf of Fuqi International, Inc., a Delaware corporation (the “Company”), we hereby submit for filing pursuant to Rule 101(a) of Regulation S-T, the Company’s Registration Statement on Form S-1 (the “Form S-1”). Please note that in accordance with Rule 457(p) promulgated under the Securities Act of 1933, as amended, a filing fee in the amount of $1,842 was paid to the Commission in connection with the filing of the Form S-1. We are also forwarding to your attention and to Anita Karu and Sarah Goldberg courtesy copies of the Form S-1 and a copy of this letter.
As you will note, the Form S-1 contains reference to certain information derived from industry surveys and other market sources. In order to expedite the Commission’s review of the Form S-1, we are enclosing the following supplemental information, with cross-references indicated to the page and paragraph of the Form S-1 where such industry data appear.
Location in Registration Statement | Statement | Source |
| Prospectus Summary, Overview, paragraph 1 & Business, Overview, paragraph 1 | “According to Global Industry Analysts, Inc., or GIA, China’s jewelry industry grew to $14 billion in 2005 and China is expected to lead global jewelry processing and consumption by 2010.” | Precious Jewelry, GIA report pg. III-64 first paragraph. |
Securities and Exchange Commission
July 2, 2007
Page 2
Location in Registration Statement | Statement | Source |
| Prospectus Summary, Industry Background, paragraph 1 & Business, Industry Background, China’s growing consumer market, paragraph 1 | “According to the Economist Intelligence Unit (EIU), China’s nominal gross domestic product, or GDP, grew by 10.1%, 10.4% and 10.7% in 2004, 2005 and 2006, respectively. Economic growth in China has led to greater levels of personal disposable income and increased spending among China’s expanding middle-class consumer base.” | China - US Economy Data.xls - Data was exported from the Economist Intelligence Unit Country database - in cells V3-X3 |
| Prospectus Summary, Industry Background, paragraph 1 & Business, Industry Background, China’s growing consumer market, paragraph 1 | “According to the EIU, private consumption has grown at a 9% compound annual growth rate, or CAGR, over the last decade.” | China - US Economy Data.xls - Data was exported from the Economist Intelligence Unit Country database - calculation of ’95-’06 CAGR in cell: Z 49 |
| Prospectus Summary, Industry Background, paragraph 1 | “According to Global Industry Analysts, Inc. (GIA), the precious jewelry market in China has increased by 35% from 2001, reaching $14.9 billion in 2006. The total market size for precious jewelry is expected to exceed $18.2 billion in 2010.” | Precious Jewelry, GIA report pg. III-64 first paragraph. |
| Business, Industry Background, China’s growing jewelry market, paragraph 1 | According to GIA, the precious jewelry market in China has increased by 35% from 2001, reaching $14.9 billion in 2006. | Precious Jewelry, GIA report pp III-64 first paragraph. |
| Business, Industry Background, China’s growing consumer market, paragraph 2 | “However, with a population of 1.3 billion people, China’s economic output and consumption rates are still small on a per capita basis compared to developed countries.” | China - US Economy Data.xls - Data was exported from the Economist Intelligence Unit Country database -cell: X 10 |
Securities and Exchange Commission
July 2, 2007
Page 3
Location in Registration Statement | Statement | Source |
| Business, Industry Background, China’s growing consumer market, paragraph 2 | “In 2006, China’s GDP per capita was $7,530, as compared to GDP per capita of $44,244 in the United States. Per capita disposable income in China has grown at a CAGR of 9.8% over the last decade, rising to $728 in 2006, as compared to $9,522.8 in the United States.” | China - US Economy Data.xls - Data was exported from the Economist Intelligence Unit Country database - in cells: Y 48 and Y59 |
| Business, Industry Background, China’s growing consumer market, table 1 | “The following table sets forth a summary of certain data regarding China’s economic growth for the years from 2002 to 2006.” [see table] | China - US Economy Data.xls - Data was exported from the Economist Intelligence Unit Country database - Row 44-48, 18 |
| Business, Industry Background, China’s growing consumer market, table 2 | “The following table sets forth a summary of certain projections regarding China’s economic growth for the periods from 2007 to 2011.” [see table] | China - US Economy Data.xls - Data was exported from the Economist Intelligence Unit Country database - Row 44-48, 18 |
| Business, Industry Background, China’s growing consumer market, paragraph 3 | “Income expanded for both urban and rural populations in 2006. According to the EIU, in 2006 disposable income per capita for urban residents averaged $1,475, an increase of 12% from 2005, while those of rural residents reached $449, an increase of 10% from 2005.” | EIU China Country Report pg. 26, second paragraph from the bottom ($449 is a calculation using RMB11,759 (US$1,475 ratio on the same page) and RMB3,587 |
| Business, Industry Background, China’s growing jewelry market, paragraph 1 | “According to the same source, China is becoming one of the largest consumers of gold jewelry in the world by volume, consuming more than 198 tons of gold jewelry in 2002.” | Precious Jewelry, GIA report pp II-19, Table 5, China line 2002 data. |
Securities and Exchange Commission
July 2, 2007
Page 4
Location in Registration Statement | Statement | Source |
| Business, Industry Background, China’s growing jewelry market, paragraph 2 | “Gold is the largest segment in China’s precious jewelry market, followed by platinum and diamond jewelry. According to GIA, jewelry has become the third largest consumption item in China after automobiles and housing. The total market size for precious jewelry is expected to exceed $18.2 billion in 2010.” | Precious Jewelry, GIA report pg. III-64, first paragraph. |
| Business, Industry Background, China’s growing jewelry market, chart 1 | “The following charts set forth certain data and projections on the size and composition of China’s jewelry market.” [see chart] | Precious Jewelry, GIA report pg. III-67, Table 79. |
| Business, Industry Background, Other factor’s driving the growth of China’s jewelry market, paragraph 4 | “China’s entry into the World Trade Organization has lead to lower tariffs, an easing of trade regulations, and the opening of China’s jewelry market to foreign investors. According to GIA, as a result of these factors, China is set to lead global jewelry processing and consumption by 2010.” | Precious Jewelry, GIA report, page III-64, first paragraph, second sentence under heading “Macroeconomic Trends.” |
| Business, Industry Background, Other factor’s driving the growth of China’s jewelry market, paragraph 5 | “According to the National Bureau of Statistics of China, China’s urban population as a percentage of total population increased from 17.9% in 1978 to 29.0% in 1995 and to 43.0% in 2005, and is projected to continue to grow rapidly” | China Statistical Yearbook (2006), pg. 99 |
| Business, Industry Background, Other factor’s driving the growth of China’s jewelry market, paragraph 5 | “According to the National Bureau of Statistics, 78.3% of retail sales for consumer goods took place in urban areas in 2005. Retail sales in urban areas grew by 13.5% in 2005, compared to growth in rural areas of 10.8% over the same period.” | China Statistical Yearbook (2006), pg. 678 |
Securities and Exchange Commission
July 2, 2007
Page 5
Location in Registration Statement | Statement | Source |
| Business, Industry Background, Other factor’s driving the growth of China’s jewelry market, paragraph 6 | “According to the China City Statistics Yearbook (2006), China had over 120 cities each with a population of over four million, as of the end of 2005. | China City Statistical Yearbook (2006), pgs. 22, 29-36 |
| Quantitative and Qualitative Disclosure about Market Risk, Inflation | “According to the National Bureau of Statistics of China, the change in Consumer Price Index in China was 3.9% and 1.8% in 2004 and 2005, respectively.” | China Statistical Yearbook (2006), pg. 315 |
| Business, Our Strategies, Establish and expand our retail market footprint, paragraph 4, bullet point 3 | · growing jewelry market—China’s jewelry market has recently experienced significant growth. According to research done by India's Gems and Jewelry Export Promotion Council (GJEPC) in 2006, the Chinese gems and jewelry market is growing at the rate of 8-10% annually. | GJEPC: Useful Information - A Report on the Delegation Visit to China & Hong Kong, pg. 8 & GJEPC: Gem and Jewelry Market Focus: China, Potential and Burgeoning Market; pg. 1 |
Should you have any questions or require any additional information with respect to this filing, please contact the undersigned at 310-552-5000 or by facsimile at 310-552-5001.
Sincerely,
/s/ Thomas J. Poletti
Thomas J. Poletti
Enclosures
cc: Anita Karu
Sarah Goldberg
