Replies to post #155618 on Sino Agro Food Inc (fka SIAF)

[TheNorwegian]

You mean this comment from SEC?

We note your response to comment three and the details you provided regarding the
valuation of the property and intellectual assets cited in the Appendices of the Investment
Agreement. During our January 4, 2018 conference call with you, you indicated that the
valuations represent historical construction cost, some of which are supported by
subsequent third party appraisals. Furthermore, you stated that intellectual properties
represent operator licenses, for which cash has been paid upfront for license periods up to
50 years. Please confirm the valuation methods used for each group of assets. As part of
your response, please clarify which assets have received appraisals, and when these
appraisals were obtained. Finally, for intellectual properties, please provide the details of
the upfront cash payments, the pertinent amortization schedules, and remaining useful
lives for which you expect to benefit from.