Boustead Securities, LLC
6 Venture, Suite 325
Irvine, CA 92618
June 30, 2017
VIA EDGAR
Division of Corporation Finance
SECURITIES AND EXCHANGE COMMISSION
100 F Street, N.E.
Washington, DC 20549
Attention: Pamela Long
| Re: | ZK International Group Co., Ltd.. |
Registration Statement on Form F-1
(File No. 333-218198)
Dear Ms. Long:
Acting on behalf of the several underwriters, we hereby join in the request of ZK International Group Co., Ltd.. that the effective date of the above-captioned Registration Statement be accelerated so that it will become effective at 5:30 p.m., Eastern Time, on June 30, 2017, or as soon thereafter as practicable.
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Securities Act"), each of the undersigned affirms that it is aware of its obligations under the Securities Act in connection with this offering.
| Very Truly Yours, |
| By: Boustead Securities, LLC |
| | |
| By: | /s/ Keith Moore |
| Name: | Keith Moore |
| Title: | Chief Executive Officer |