CORRESP for the SEC letter of the Registration Satement on Form S-1 Achison INC CIK: 0001672571 3906 Main Street, 207 Flushing, NY11354May 17, 2017VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate and Commodities 100 F Street, N.E. Washington, DC 20549 Attention: Folake Ayoola Stacie Gorman Paul Cline Wilson Lee Re: Achison Inc Amendment No. 7 to Registration Satement on Form S-1 Filed April 21, 2017 File No. 333-211051 General 1. We note your response to our prior comment 1 and continue to note your disclosure that Lansdale Inc. will intend to hold sufficient shares to become the parent of the Corporation. (emphasis added) Please revise your disclosure to clarify whether you have entered into an oral or written agreement or understanding to sell securities to Lansdale in this public offering. If so, please tell us how this complies with Section 5 of the Securities Act. Alternatively, please revise your disclosure to so clarify. Please see the amended contents of the Prospectus Summary 4 on page 6 of the Form S-1/A on May 17, 2017. Exhibit 23 2. Please refer to prior comment 5 and revise to include an updated consent for the audit report issued on the financial statements at and for the period ended March 31, 2015. Be advised that the consents for both audit reports included in the registration statement are required to be current at the time effectiveness is requested. Please see the amended contents of Exhibits 23.3 of the Form S-1/A on May 17, 2017. Wanjun Xie Wanjun Xie President Achison Inc Date: AMay 17, 2017 |