ZHONGPIN INC.
21 Changshe Road, Changge City
Henan Province, PRC
February 2, 2007
VIA EDGAR & FACSIMILE (202-772 -9202)
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Attention: Filing Desk
John Reynolds, Assistant Director,
Office of Small Business Policy
Re: Zhongpin Inc.
Registration Statement on Form S-1
REGISTRATION STATEMENT NO. 333-140190
Ladies and Gentlemen:
Zhongpin Inc. hereby requests that the effective date for the
above-referenced registration statement be accelerated so that it will be
declared effective by 2:00 p.m., New York City time, on Friday, February 2,
2007, or as soon thereafter as is practicable.
In connection with this request, the Company hereby acknowledges that:
1. should the Securities and Exchange Commission (the
"Commission") or the Commission staff, acting
pursuant to delegated authority, declare the
Registration Statement effective, the Commission
shall not be foreclosed from taking any action with
respect to the Registration Statement;
2. the action of the Commission or the Commission staff,
acting pursuant to delegated authority, in declaring
the Registration Statement effective, does not
relieve the Company from its full responsibility for
the adequacy and accuracy of the disclosures in the
Registration Statement; and
3. the Company may not assert the acceleration of the
effectiveness of the Registration Statement pursuant
to this request as a defense in any proceeding
initiated by the Commission or any person under the
federal securities laws of the United States.
Division of Corporation Finance
Securities and Exchange Commission
February 2, 2007
Page 2
Please notify Eric M. Hellige of Pryor Cashman Sherman & Flynn LLP at
212-326-0846 when the Registration Statement is declared effective.
Very truly yours,
ZHONGPIN INC.
By: /s/ Xianfu Zhu
-----------------------------
Name: Xianfu Zhu
Title: Chief Executive Officer