-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, I+M0BDQlTGz4U2mN8OOr+aRnRTax3o+GknD77MLleL3rI+Wfp3lxZXpplvZNadbh z9dlFzlJ8fZKvmmOndmlhA== 0001144204-09-030791.txt : 20090814 0001144204-09-030791.hdr.sgml : 20090814 20090603170235 ACCESSION NUMBER: 0001144204-09-030791 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090603 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SKYSTAR BIO-PHARMACEUTICAL CO CENTRAL INDEX KEY: 0001076939 STANDARD INDUSTRIAL CLASSIFICATION: PHARMACEUTICAL PREPARATIONS [2834] IRS NUMBER: 330901534 STATE OF INCORPORATION: NV FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: RM 10601, JIEZUO PLAZA, NO. 4 STREET 2: FENGHUI ROAD SOUTH, GAOXIN DISTRICT CITY: XIAN PROVINCE STATE: F4 ZIP: 00000 BUSINESS PHONE: 407-645-4433 MAIL ADDRESS: STREET 1: RM 10601, JIEZUO PLAZA, NO. 4 STREET 2: FENGHUI ROAD SOUTH, GAOXIN DISTRICT CITY: XIAN PROVINCE STATE: F4 ZIP: 00000 FORMER COMPANY: FORMER CONFORMED NAME: CYBER GROUP NETWORK CORP DATE OF NAME CHANGE: 20000711 CORRESP 1 filename1.htm
Richardson & Patel LLP
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Los Angeles, California 90024
Tel: (310) 208-1182
Fax: (310) 208-1154


June 3, 2009


FILED AS EDGAR CORRESPONDENCE

Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549-6010
Attn: Jennifer Riegel


Re:
Skystar Bio-Pharmaceutical Company
Registration Statement on Form S-1/A
Filed June 2, 2009
File No. 333-150695

Dear Ms. Riegel:

I am writing to you on behalf of Skystar Bio-Pharmaceutical Company (the “Company”) regarding Amendment No. 8 of its registration statement on Form S-1/A filed with the Commission on June 2, 2009. As you may recall, Amendment No. 7, which was filed with the Commission on January 29, 2009, was on the verge of becoming effective, having cleared all of the Commission’s extensive comments (through six earlier amendments of the registration statements) excepting one regarding the correct number of common shares Mr. Bennet Tchaikovsky was entitled to receive under his agreement with the Company.

Substantively, the disclosures in Amendment No. 8 are nearly identical to those in Amendment No. 7 except to address the outstanding comment described above and for certain updates as warranted by the passage of time, including the audited financial statements for the year ended December 31, 2008 and the reviewed financial statements for the quarter ended March 31, 2009, as well as the related management’s discussion and analysis of these periods. These updated disclosures, however, have been prepared with the Commission’s prior comments to the registration statement in mind. Accordingly, we respectfully request, on behalf of the Company, that Amendment No. 8 be subject to no additional review or, alternatively, be reviewed on an expedited basis.

 
 
 
Ms. Jennifer Riegel
Securities and Exchange Commission
June 3, 2009
 
 
Your consideration of this request is greatly appreciated. If you have any questions, please do not hesitate to contact the undersigned by telephone at (310) 208-1182, by facsimile at (310) 208-1154, or by electronic mail at fchen@richardsonpatel.com. Thank you.

   
 
Very truly yours,
   
 
 RICHARDSON & PATEL, LLP
   
 
/s/ Francis Chen
   
 
 Francis Chen, Esq.

 
 
 
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