Eason Technology Ltd — Regulatory Filings 2016

Feb 16, 2016

CORRESP 1 filename1.htm xny_corresp.htm Document Created by EDGARMaster

February 16 , 201 6

VIA EDGAR

CONFIDENTIAL

Mr. Rufus Decker, Accounting Branch Chief

Ms. Linda Cvrkel

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington , D.C. 20549

| Re: |
| --- |
| Form 20-F for Fiscal Year Ended December 31, 2014 |
| Filed April 28, 2015 |
| Response dated January 15 , 201 6 |
| File No. 1-34958 |

Dear Mr. Decker and Ms. Cvrkel:

China Xiniya Fashion Limited (the "Company") thanks the staff of the Securities and Exchange Commission (the "Staff") for its letter dated February 5, 2016 and its review of and comments on the Company's annual report on Form 20-F filed on April 28, 2015 (the "2014 Annual Report"). In response to the Staff's comments, the Company will reflect in its Annual Report on Form 20-F for the year ended 2015 the financial statement revisions requested by the Staff, including the requested reclassification adjustments to sales and costs of sales amounts in the 2014 financial statements to reflect the change in estimate and to account for the subsequent resales in the same manner as the other sales.

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If you have any questions regarding this submission, please contact our compliance counsel, Mr. Alan Seem of Shearman & Sterling LLP, at +1-650-838-3753 or aseem@shearman.com or contact me at ngcheejiong@xiniya.com.

Very truly yours,
/s/ Chee Jiong Ng
Chee Jiong Ng
Chief Financial Officer

Enclosures

cc:
Alan Seem, Shearman & Sterling LLP