0001144204-19-020666.txt : 20190423 0001144204-19-020666.hdr.sgml : 20190423 20190423115903 ACCESSION NUMBER: 0001144204-19-020666 CONFORMED SUBMISSION TYPE: RW PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20190423 DATE AS OF CHANGE: 20190423 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Imperial Garden & Resort, Inc. CENTRAL INDEX KEY: 0001688470 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MISCELLANEOUS AMUSEMENT & RECREATION [7990] IRS NUMBER: 000000000 STATE OF INCORPORATION: D8 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: RW SEC ACT: SEC FILE NUMBER: 333-216694 FILM NUMBER: 19761048 BUSINESS ADDRESS: STREET 1: 106 ZHOUZI STREET STREET 2: 4TH FLOOR CITY: TAIPEI STATE: F5 ZIP: 11493 BUSINESS PHONE: 886-2-26582927 MAIL ADDRESS: STREET 1: 106 ZHOUZI STREET STREET 2: 4TH FLOOR CITY: TAIPEI STATE: F5 ZIP: 11493 RW 1 tv519470_rw.htm RW

April 23, 2019

VIA EDGAR

Julie Griffith

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re:

Request to Withdraw the Registration Statement on Form S-1 Registration Number 333-216694

Ladies and Gentlemen:

On October 28, 2016, Imperial Garden & Resort, Inc., a British Virgin Islands company (the “Company”), filed a draft Registration Statement on Form F-1 (together with the amendments and exhibits thereto, the “Registration Statement”) with the Securities and Exchange Commission (the “Commission”), which was declared effective on March 12, 2018.

Pursuant to Rule 477 under the Securities Act of 1933, as amended (the “Act”), the Company hereby applies for the withdrawal of the Registration Statement and requests that the Commission consent thereto.

The Company has determined at this time not to proceed with the offering as contemplated by the Registration Statement and requests that the Commission consent to this application on the grounds that withdrawal of the Registration Statement is consistent with the public interest and the protection of investors, as contemplated by paragraph (a) of Rule 477. Although the Registration Statement had been declared effective by the Commission, no securities were sold under the Registration Statement.

It is our understanding that this application for withdrawal of the Registration Statement will be deemed granted as of the date that it is filed with the Commission unless, within fifteen days after such date, the Company receives notice from the Commission that this application will not be granted.

In accordance with Rule 457(p) of the Securities Act, the Registrant requests that all fees paid to the Commission in connection with the filing of the Registration Statement be credited for future use.

If you have any questions regarding this letter, please contact the Company’s legal counsel, Jay Kaplowitz, Esq. of Sichenzia Ross Ference LLP at 212-930-9700.

	Very truly yours,

	Imperial Garden & Resort, Inc.

	By:	/s/ Fun-Ming Lo
		Fun-Ming Lo
		Chief Executive Officer