[Recon Technology, Ltd August 9, 2010 VIA EDGAR Division of Corporation Finance 100 F Street, N.E. Attn: H. Roger Schwall, Assistant Director Re: Form RW With Respect to Withdrawal of Registration Statement on Form S-1 (File No. 333-166540) Dear Mr. Schwall: Very truly yours, Recon Technology, Ltd RW 1 drw.htm WITHDRAWL OF REGISTRATION]
[SUBJECT TO COMPLETION, DATED JUNE 22, 2010 RECON TECHNOLOGY, LTD Risk Factors Investing in these units involves significant risks. See Per Unit Total] [[ ] Units RECON TECHNOLOGY, LTD UNDERWRITING AGREEMENT June [ ], 2010 LADENBURG THALMANN & CO. INC. 520 Madison Avenue New York, NY 10022 As Representative of the Underwriters Schedule A named on Ladies and Gentlemen: Company Underwriters Representative Firm Units Ordinary Shares Recon Technology, Ltd, a corporation organized and existing under the laws of the Cayman Islands (the ] [6 00620**Shares****600620**Shares****600620**Shares****600620**Shares****600620**Shares ****600620**Shares****600620**Shares****600620**Shares****60 * * * SIX HUNDRED THOUSAND 0620**Shares****600620**Shares****600620**Shares****600620**Shares****600620**Shares ****600620**Shares****600620**Shares****600620**Shares**** 600 620**Shares****600620**Shares****600620**Shares****600620**Shares****600620**Shares ****600620**Shares***600620**Shares****600620**Shares****] [Kaufman & Canoles, P.C. Three James Center, 12 th Floor 1051 East Cary Street Richmond, VA 23219 Mailing Address Post Office Box 27828 Richmond, VA 23261 T (804) 771.5700 F (804) 771.5777 kaufCAN.com June 22, 2010 Recon Technology, Ltd Kinglong International Mansion Fulin Rd 9, Chaoyang District, Beijing, PRC 100107 Re: Recon Technology, Ltd Dear Sir: Sincerely, Kaufman & Canoles,] [Recon Technology, Ltd. W I T N E S S E T H WHEREAS WHEREAS WHEREAS NOW, THEREFORE Certain Definitions Section 1. provided however (c) Close of Business on any given date means 5:00 p.m., New York City time, on such date; (d) Effective Date means (g) Initial Exercise Price means $ (h) Person means an individual, corporation, association, partnership,] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors Recon Technology, Ltd. As an independent registered public accounting firm, we hereby consent to the use of our report on the financial statements of Recon Technology, Ltd., dated September 23, 2009 with respect to the consolidated and combined balance sheets of Recon Technology, Ltd. as of June 30,]
[SUBJECT TO COMPLETION, DATED JUNE 22, 2010 RECON TECHNOLOGY, LTD Risk Factors Investing in these units involves significant risks. See Per Unit Total] [[ ] Units RECON TECHNOLOGY, LTD UNDERWRITING AGREEMENT June [ ], 2010 LADENBURG THALMANN & CO. INC. 520 Madison Avenue New York, NY 10022 As Representative of the Underwriters Schedule A named on Ladies and Gentlemen: Company Underwriters Representative Firm Units Ordinary Shares Recon Technology, Ltd, a corporation organized and existing under the laws of the Cayman Islands (the ] [6 00620**Shares****600620**Shares****600620**Shares****600620**Shares****600620**Shares ****600620**Shares****600620**Shares****600620**Shares****60 * * * SIX HUNDRED THOUSAND 0620**Shares****600620**Shares****600620**Shares****600620**Shares****600620**Shares ****600620**Shares****600620**Shares****600620**Shares**** 600 620**Shares****600620**Shares****600620**Shares****600620**Shares****600620**Shares ****600620**Shares***600620**Shares****600620**Shares****] [Kaufman & Canoles, P.C. Three James Center, 12 th Floor 1051 East Cary Street Richmond, VA 23219 Mailing Address Post Office Box 27828 Richmond, VA 23261 T (804) 771.5700 F (804) 771.5777 kaufCAN.com June 22, 2010 Recon Technology, Ltd Kinglong International Mansion Fulin Rd 9, Chaoyang District, Beijing, PRC 100107 Re: Recon Technology, Ltd Dear Sir: Sincerely, Kaufman & Canoles,] [Recon Technology, Ltd. W I T N E S S E T H WHEREAS WHEREAS WHEREAS NOW, THEREFORE Certain Definitions Section 1. provided however (c) Close of Business on any given date means 5:00 p.m., New York City time, on such date; (d) Effective Date means (g) Initial Exercise Price means $ (h) Person means an individual, corporation, association, partnership,] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors Recon Technology, Ltd. As an independent registered public accounting firm, we hereby consent to the use of our report on the financial statements of Recon Technology, Ltd., dated September 23, 2009 with respect to the consolidated and combined balance sheets of Recon Technology, Ltd. as of June 30,]
[SUBJECT TO COMPLETION, DATED JUNE 9, 2010 RECON TECHNOLOGY, LTD Risk Factors Investing in these units involves significant risks. See Per Unit] [1,000,000 Units RECON TECHNOLOGY, LTD UNDERWRITING AGREEMENT June [ ], 2010 LADENBURG THALMANN & CO. INC. 520 Madison Avenue New York, NY 10022 As Representative of the Underwriters Schedule A named on Ladies and Gentlemen: Company Underwriters Representative Firm Units Ordinary Shares Recon Technology, Ltd, a corporation organized and existing under the laws of the Cayman Islands (the UPO] [Scotia Centre P.O. Box 884 Grand Cayman KY1-1103 CAYMAN ISLANDS Tel: (345) 949-2648 Fax: (345) 949-8613 www.campbells.com.ky Your Ref: Our Ref: Direct Email: Direct Line: ID/vg idillon@campbells.com.ky 8 June 2010 Recon Technology, Ltd Room 1401 Yong Feng Mansion 123 Jiqing Road Nanjing Peoples Republic of China 210006 Dear Sir RECON TECHNOLOGY, LTD In connection with rendering our opinion as set] [Kaufman & Canoles, P.C. Three James Center, 12 th Floor 1051 East Cary Street Richmond, VA 23219 Mailing Address Post Office Box 27828 Richmond, VA 23261 T (804) 771.5700 F (804) 771.5777 kaufCAN.com June 9, 2010 Recon Technology, Ltd Kinglong International Mansion Fulin Rd 9, Chaoyang District, Beijing, PRC 100107 Re: Recon Technology, Ltd Dear Sir: Sincerely, Kaufman & Canoles,] [LOCK-UP AGREEMENT June [ ], 2010 Ladenburg Thalmann & Co. Inc. 520 Madison Avenue, New York NY 10022 Ladies and Gentlemen: Ladenburg Company Offering Unit Lock-up Period Ordinary Shares Beneficially Owned Shares In order to induce Ladenburg Thalmann & Co. Inc. (the If (i) the Company issues an earnings release or material news or a material event relating to] [ANSEN ARNETT AXWELL P C H A Professional Corporation CERTIFIED PUBLIC ACCOUNTANTS Registered with the Public Company Accounting Oversight Board 5 Triad Center, Suite 750 Salt Lake City, UT 84180-1128 Phone: (801) 532-2200 Fax: (801) 532-7944 www.hbmcpas.com CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors Recon Technology, Ltd. As an independent registered public accounting firm, we] [June 8, 2010 Recon Technology, Ltd Room 1902, Building C Kinglong International Mansion Fulin Rd 9, Chaoyang District, Beijing, PRC 100107 Dear Sirs, PRC We are qualified lawyers of the Peoples Republic of China (the Company Registration Statement SEC Securities Act We have acted as PRC counsel for Recon Technology, Ltd, a company incorporated under the laws of the Cayman]
[] [CERTIFICATION I, Yin Shenping, certify that: (1) I have reviewed this Quarterly Report on Form 10-Q of Recon Technology, Ltd; (2) Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were] [CERTIFICATION I, Liu Jia, certify that: (1) I have reviewed this Quarterly Report on Form 10-Q of Recon Technology, Ltd; (2) Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were] [18 U.S.C. SECTION 1350, SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002 2. The information contained in the Report fairly presents, in all material respects, the condensed consolidated financial condition and results of operations of the Company. May 17, 2010 Yin Shenping Chief Executive Officer EX-32.1 4 dex321.htm SECTION 906 CEO CERTIFICATION] [18 U.S.C. SECTION 1350, SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002 2. The information contained in the Report fairly presents, in all material respects, the condensed consolidated financial condition and results of operations of the Company. May 17, 2010 Liu Jia Chief Financial Officer EX-32.2 5 dex322.htm SECTION 906 CFO CERTIFICATION]
[] [CERTIFICATION I, Yin Shenping, certify that: (1) I have reviewed this Quarterly Report on Form 10-Q of Recon Technology, Ltd; (2) Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were] [CERTIFICATION I, Liu Jia, certify that: (1) I have reviewed this Quarterly Report on Form 10-Q of Recon Technology, Ltd; (2) Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were] [18 U.S.C. SECTION 1350, SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002 2. The information contained in the Report fairly presents, in all material respects, the condensed consolidated financial condition and results of operations of the Company. May 17, 2010 Yin Shenping Chief Executive Officer EX-32.1 4 dex321.htm SECTION 906 CEO CERTIFICATION] [18 U.S.C. SECTION 1350, SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002 2. The information contained in the Report fairly presents, in all material respects, the condensed consolidated financial condition and results of operations of the Company. May 17, 2010 Liu Jia Chief Financial Officer EX-32.2 5 dex322.htm SECTION 906 CFO CERTIFICATION]
[RECON TECHNOLOGY, LTD Investing in these units involves significant risks. See Risk Factors beginning on page 8 of this prospectus. Per Unit Total Public offering price $ $ Underwriting discounts and commissions $ $ Proceeds to us, before expenses] [ANSEN ARNETT AXWELL P C H A Professional Corporation Registered with the Public Company CERTIFIED PUBLIC ACCOUNTANTS Accounting Oversight Board 5 Triad Center, Suite 750 Salt Lake City, UT 84180-1128 Phone: (801) 532-2200 Fax: (801) 532-7944 www.hbmcpas.com CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors Recon Technology, Ltd. As an independent registered public accounting firm, we]
[RECON TECHNOLOGY, LTD Investing in these units involves significant risks. See Risk Factors beginning on page 8 of this prospectus. Per Unit Total Public offering price $ $ Underwriting discounts and commissions $ $ Proceeds to us, before expenses] [ANSEN ARNETT AXWELL P C H A Professional Corporation Registered with the Public Company CERTIFIED PUBLIC ACCOUNTANTS Accounting Oversight Board 5 Triad Center, Suite 750 Salt Lake City, UT 84180-1128 Phone: (801) 532-2200 Fax: (801) 532-7944 www.hbmcpas.com CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM To the Board of Directors Recon Technology, Ltd. As an independent registered public accounting firm, we]
[Recon Technology Secures $1.2M in New Equipment and Chemical Orders for Chinese Oil and Gas Fields Beijing, China March 8, 2010 Recon received an RMB 1,493,973 (approximately $219,000 USD) order from the CNPC Changqing Sulige Gas Field in Inner Mongolia. This includes various gas and oil field chemicals, such as gas well cleanup additive, clay stabilizer, crosslinking agent, foaming] []
[Recon Technology Secures $1.2M in New Equipment and Chemical Orders for Chinese Oil and Gas Fields Beijing, China March 8, 2010 Recon received an RMB 1,493,973 (approximately $219,000 USD) order from the CNPC Changqing Sulige Gas Field in Inner Mongolia. This includes various gas and oil field chemicals, such as gas well cleanup additive, clay stabilizer, crosslinking agent, foaming] []
