July 3, 2019
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing and Construction
100 F. Street NE
Washington, DC 20549
Attention: Sisi Cheng and Kevin Stertzel
| Re: | ZK International Group Co., Ltd. |
| Form 20-F for Fiscal year Ended September 30, 2018 | |
| Filed January 31, 2019 | |
| File No. 001-38146 |
Dear Ms. Chen and Mr. Stertzel:
Reference is made to the letter (the “Comment Letter”) dated June 4, 2019, containing comments of the Staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission on ZK International Group Co., Ltd.’s Annual Report on Form 20-F for the fiscal year ended September 30, 2018. We submitted a letter on June 18, 2019 on behalf of ZK International Group Co., Ltd. (the “Company”) to request a ten (10) business day extension of the deadline for responding to the Comment Letter. We submit this letter on behalf of the Company to request an additional three (3) business day extension of the deadline in order to allow the Company additional time to gather necessary information and respond fully to the Comment Letter. This letter confirms that the Company anticipates submitting its response to the Comment Letter on or before July 8, 2019.
If you have any questions, please do not hesitate to contact William S. Rosenstadt, Esq. or Mengyi "Jason" Ye, Esq. at wsr@orllp.legal or jye@orllp.legal.
Sincerely,
| Very truly yours, | |
| /s/ Ortoli Rosenstadt | |
| Ortoli Rosenstadt LLP |
| cc: | Di Chen, Corporate Secretary, ZK International Group Co., Ltd. |