Organic Agricultural Company Limited (OGAA)
Filed: 15 Oct 18, 12:00am
 | Organic Agricultural Company Limited |
| October 15, 2018 |
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, D.C. 20549
| Attention: | Melissa Gilmore |
Jean Yu
Sonia Bednarowski
Laura Nicholson
| Re: | Organic Agricultural Company Limited |
Amendment No. 1 to Registration Statement on Form S-1
Filed September 28, 2018
File No. 333-226810
Ladies and Gentlemen,
Organic Agricultural Company Limited (the “Company” or “OACL”), hereby furnishes herewith the following correspondence in connection with the Company’s filing today of Amendment No.2 (the “Amendment”) to the Company’s Registration Statement on Form S-1. Set forth below in italics you will find copies of the Staff’s comment from its letter dated October 12, 2018 (the “Comment Letter”), followed by information and page reference to the location within the Amendment where responsive disclosure can be found.
Amendment No. 1 to Registration Statement on Form S-1
Business of the Company
Farmland Leases, page 28
| 1. | We note your revised disclosure in response to our prior comment 7. Please disclose the termination provisions in your lease agreements, if material. |
United States Securities and Exchange Commission
October 15, 2018
Page 2
Response to Comment 1:
As requested, we have edited the text regarding the farmland leases at page 28 as follows:
Each of the 300 farmland leases was drawn on the same form. The lease permits an affiliate of Lvxin to conduct production operations on an identified parcel of farmland for a stated period of years, up to 22 years in some leases. There are no specific provisions for termination of the leases other than upon expiration of the stated term; accordingly, a party may terminate a lease during its term only pursuant to such provisions of law as permit termination in the event of a material irremediable breach. The leases provide for a fixed rental amount, which is paid either annually on January 1 or, in some cases, prepaid for periods from 12 to 22 years. The leases assign to Lvxin the right to receive any special subsidy that the PRC may issue from time to time. The parties agree to negotiate, should any issues arise with respect to the leasehold.
Please advise us if you have any further questions or comments.
Respectfully submitted
/s/Jianjun Xun
Jianjun Xun
Chief Executive Officer