October 15, 2009
VIA EDGAR and FACSIMILE (202-772-9205)
Larry Spirgel Assistant Director United States Securities and Exchange Commission Division of Corporation Finance 100 F Street NE Mail Stop 3720 Washington, DC 20549 |
Registration Statement on Form S-1
File No. 333-160343
Ladies and Gentlemen:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, ZST Digital Networks, Inc., a Delaware corporation (the “Company”), hereby requests that the Securities and Exchange Commission take appropriate action to cause the above-referenced Registration Statement to become effective at 5:30 p.m. Eastern time on Monday, October 19, 2009, or as soon thereafter as practicable.
The Company acknowledges that:
· | should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
· | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
· | the company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Should you have any questions or require any additional information with respect to this filing, please contact Ayla A. Nazli, Esq. at (310) 552-5565 or by facsimile at (310) 552-5578.
Thank you for your assistance and cooperation.
Best regards,
ZST DIGITAL NETWORKS, INC.
/s/ Zhong Bo
By: Zhong Bo
Title: Chief Executive Officer
cc: | Scott Hodgdon, Securities and Exchange Commission |
Thomas J. Poletti, Esq., K&L Gates
Ayla A. Nazli, Esq., K&L Gates