CORRESP for the SEC letter of the Registration Satement on Form S-1 Achison INC CIK: 0001672571 3906 Main Street, 207 Flushing, NY11354June 29, 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 May 18, 2017 File No. 333-211051 General 1. Please confirm that you reasonably expect to offer and sell the registered $99.9 billion shares of common stock in the next two years. Refer to Rule 415(a)(2). Please see the amended contents on page 1 of Form S-1/A on June 29, 2017. Please see the removed contents of the Undertakings on pages 29 of Form S-1/A on June 29, 2017. 2. Please revise to update the financial statements through the fiscal quarter ended March 31, 2017 in accordance to Rule 8-08 of Regulation S-X. Please see the amended contents of the Financial Statement on pages 12 of Form S-1/A on June 29, 2017. Exhibit 23 3. Please include updated consents from your independent accountants in your next preeffective amendment. Please be advised that the consents for the inclusion of the reports from your independent accountants in the registration statement prior to effectiveness should not be older than 30 days. Please see Exhibits 23.1, 23.2 and 23.3 of Form S-1/A on June 29, 2017. Wanjun Xie Wanjun Xie President Achison Inc Date: June 29, 2017 |