PEARLMAN SCHNEIDER LLP
Attorneys-at-Law
2200 Corporate Boulevard, N.W., Suite 210
Boca Raton, Florida 33431-7307
James M. Schneider, Esq. (561) 362-9595 Charles B. Pearlman, Esq. Facsimile Brian A. Pearlman, Esq. (561) 362-9612
Telephone
February 12, 2014
“CORRESP’
Via EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
|
Re: |
Armco Metals Holdings, Inc. (the “Company”) |
Ladies and Gentlemen:
The Company is in receipt of the staff’s letter of comment dated February 12, 2014. Below are the Company’s responses. Contemporaneously, the Company has filed Amendment No. 2 to the above-captioned registration statement.
General
1. |
We note your response to our prior comment 1. Please reconcile your response with the dsiclosure in the third risk factor on page 13. |
RESPONSE: As the Company is not subject to the penny stock rules, the referenced risk factor has been removed from Amendment No. 2 in accordance with our oral discussion with Mr. Field.
We trust the foregoing sufficiently responds to the staff’s comments.
Sincerely,
/s/ James M. Schneider
James M. Schneider
Cc: Mr. Kexuan Yao