[China Agro Sciences Corp. 101 Xinanyao Street, Jinzhou District, Dalian, Liaoning Province, PRC 116100 September 4, 2009 Division of Corporation Finance 100 F Street, NE Mail Stop 4561 Attn: Mark P. Shuman, Evan S. Jacobson, Barbara C. Jacobs Fax: 703-813-6981 Tel: 202-551-3428 Re: China Agro Sciences Corp. Dear Mr. Shuman I am writing in response to your comment letter dated]
[China Agro Sciences Corp. 101 Xinanyao Street, Jinzhou District, Dalian, Liaoning Province, PRC 116100 September 4, 2009 Division of Corporation Finance 100 F Street, NE Mail Stop 4561 Attn: Mark P. Shuman, Evan S. Jacobson, Barbara C. Jacobs Fax: 703-813-6981 Tel: 202-551-3428 Re: China Agro Sciences Corp. Dear Mr. Shuman I am writing in response to your comment letter dated]
[Page Consolidated Balance Sheets as of June 30, 2009 (Unaudited) and December 31, 2008 52 Consolidated Statements of Operation for the Six Months ended June 30, 2009 and 2008 (Unaudited) 53 Consolidated Statements of Changes in Shareholders' Equity for the Six Months ended June 30, 2009 and 2008 (Unaudited) 54 Consolidated Statements of Cash Flows for the Six Months ended] [Page 75 Balance Sheets at December 31, 2008 and 2007 76 Statements of Income for the Years ended December 31, 2008 and 2007 77 Statements of Shareholders' Equity for the Years ended December 31, 2008 and 2007 78 Statements of Cash Flows for the Years ended December 31, 2008 and 2007 79 Notes to Financial Statements 80-98 74 To the] [Page Introduction to Unaudited Pro Forma Condensed Consolidated Financial Statements 100 Pro Forma Condensed Consolidated Balance Sheets as of June 30, 2009 (Unaudited) 101 Pro Forma Condensed Consolidated Statement of Operations for the Year Ended September 30, 2008 (Unaudited) 102 Pro Forma Condensed Consolidated Statement of Operations for the Nine Months Ended June 30, 2009 (Unaudited) 103 Notes to Condensed] [EXPLANATORY NOTE This current report is being filed in connection with a series of transactions consummated by the Company and certain related events and actions taken by the Company. This current report responds to the following items on Form 8-K: Item 1.01 Entry into a Material Definitive Agreement Item 2.01 Completion of Acquisition of Assets]
[Page Consolidated Balance Sheets as of June 30, 2009 (Unaudited) and December 31, 2008 52 Consolidated Statements of Operation for the Six Months ended June 30, 2009 and 2008 (Unaudited) 53 Consolidated Statements of Changes in Shareholders' Equity for the Six Months ended June 30, 2009 and 2008 (Unaudited) 54 Consolidated Statements of Cash Flows for the Six Months ended] [Page 75 Balance Sheets at December 31, 2008 and 2007 76 Statements of Income for the Years ended December 31, 2008 and 2007 77 Statements of Shareholders' Equity for the Years ended December 31, 2008 and 2007 78 Statements of Cash Flows for the Years ended December 31, 2008 and 2007 79 Notes to Financial Statements 80-98 74 To the] [Page Introduction to Unaudited Pro Forma Condensed Consolidated Financial Statements 100 Pro Forma Condensed Consolidated Balance Sheets as of June 30, 2009 (Unaudited) 101 Pro Forma Condensed Consolidated Statement of Operations for the Year Ended September 30, 2008 (Unaudited) 102 Pro Forma Condensed Consolidated Statement of Operations for the Nine Months Ended June 30, 2009 (Unaudited) 103 Notes to Condensed] [EXPLANATORY NOTE This current report is being filed in connection with a series of transactions consummated by the Company and certain related events and actions taken by the Company. This current report responds to the following items on Form 8-K: Item 1.01 Entry into a Material Definitive Agreement Item 2.01 Completion of Acquisition of Assets]
