Sino-Global Shipping America, Ltd.
136-56 39th Ave, Suite 305
Flushing, NY 11354
April 5, 2013
By EDGAR Delivery
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4631
Attention: Max A. Webb, Assistant Director and Ada D. Sarmento
Re: | Sino-Global Shipping America, Ltd. |
Preliminary Proxy Statement on Schedule 14A |
Filed March 14, 2013 |
File No. 001-34024 |
Dear Mr. Webb and Ms. Sarmento:
On behalf of Sino-Global Shipping America, Ltd. (the “Company”), we are writing to acknowledge the oral comments provided by the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) to the Company on April 4, 2013.
In response to the Staff’s comments, we have revised the proxy statement (i) to reflect that Proposal Five will be determined by a plurality of votes, (ii) to provide total director compensation, (iii) to condense the disclosure in the equity compensation plan information table from two lines to one, and (iv) to provide footnote disclosure of vesting dates in the outstanding equity awards table.
In addition, the Company acknowledges that:
· | The Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
· | Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
· | The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Sincerely,
/s/ Cao Lei
Cao Lei
Chief Executive Officer