Yambear Bio-Tech, Inc.
3F., No. 10, Yuanxi 2nd Rd.
Pingtung Agricultural Biotechnology Park
Changzhi Township, Pingtung 908
Taiwan, Republic of China
September 18, 2013
Jeffrey P. Riedler
Assistant Director
United States Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
| Re: Yambear Bio-Tech, Inc. |
| Amendment No. 3 to Registration Statement on Form S-1 |
| Filed August 2, 2013 |
| File No. 333-186689 |
Dear Mr. Riedler:
This letter responds to certain comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in the letter from the Staff to Yambear Bio-Tech, Inc. (the “Company”) dated August 14, 2013.
For your convenience, we have included each of the Staff’s comments in italics before each of the Company’s responses. References in this letter to “we,” “our” or “us” mean the Company or its advisors, as the context may require.
Financial Statements
General
Staff Comment 1:Please update your financial statements as required by Rule 8-08 of Regulation S-X.
Response: The Company has updated the financial statements as required by Rule 8-08 of Regulation S-X and has included the updated financial statements in Amendment No. 4 to the Registration Statement on Form S-1 filed concurrently with the filing of this letter.
We trust that you will find the foregoing responsive to the comments of the Staff. Comments or questions regarding this letter may be directed to the undersigned, or Ryan Nail, attorney with the Chiang Law Offices, P.C., Company counsel, at (415) 488-5581.
| Sincerely, |
| |
| |
| /s/ Hsin-Lung Lin |
| Hsin-Lung Lin |
| Chief Executive Officer |
| Yambear Bio-Tech, Inc. |
cc:
The Chiang Law Offices, P.C.
1700 North First Street, Suite 343
San Jose, CA 95112