Re: |
Yew Bio-Pharm Group, Inc. Form S-1, Filed December 7, 2012
SEC File No. 333-185320
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should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
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the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
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the company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
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Very truly yours,
YEW BIO-PHARM GROUP, INC.
By /s/ Zhiguo Wang
Zhiguo Wang
Title: President
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Re: | Yew Bio-Pharm Group, Inc. Form S-1, Filed December 7, 2012
SEC File No. 333-185320
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1.
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Please refer to the “Shares Beneficially Owned After the Offering” columns and the total percentage listed on page 103. We note your disclosure that the selling shareholders will own 100% of your common stock after the offering. We also note that the selling shareholders are offering approximately 33% of your issued and outstanding common stock. Please reconcile.
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2.
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We note that you have not named Zhiguo Wang or Guifang Qi as statutory underwriters pursuant to Section 2(a)(11) of the Securities Act of 1933. Please provide a detailed legal analysis for each explaining why this is not necessary.
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Very truly yours,
/s/ Lance Jon Kimmel
Lance Jon Kimmel
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