1701 Pennsylvania Avenue, N.W. Suite 200 Washington, D.C. 20006 Direct: 844-285-4263 ext. 758 Cell: (301) 910-2030 estern@culhanemeadows.com
Ernest M. Stern Partner |
February 22, 2022
Via EDGAR
Ms. Lauren Hamill
Division of Corporation Finance
Office of Life Sciences
U.S. Securities and Exchange Commission
Washington, D.C. 20549
Re: | Agro Capital Management Corp. | |
Draft Registration Statement No. 2 on Form S-1 | ||
Submitted February 16, 2022 | ||
CIK No. 0001598323 |
Please be advised that Agro Capital Management Inc. (the “Company”) hereby respectfully requests withdrawal of the above-mentioned Amendment 2 to the Draft Registration Statement pursuant to Rule 477 of Regulation C promulgated by the Securities and Exchange Commission (the “SEC”) under the Securities Act of 1933, as amended. The first Draft Registration Statement was filed on October 19, 2021.
The Company has been notified by SEC staff that Amendment 2 was filed as a new Form DRS and a new draft registration statement number was issued for what should be a response to the SEC comment letter dated November 18, 2021 for Draft 1 of the Form DRS. Filing a new Form DRS was inadvertent. Accordingly, since the Company wants the draft registration statement Amendment 2 to have the same draft registration statement number as the one filed on October 19, 2021, the Company respectfully requests that the SEC consent to the withdrawal of the Company’s Form DRS filed February 16, 2022 so that it can refile Amendment 2 as soon as practicable.
Please contact this office with any additional questions in this regard.
Very truly yours. | |
CULHANE MEADOWS PLLC | |
/s/ Ernest M. Stern | |
Ernest M. Stern, Partner |
Cc: Scott Benson