December 5, 2017

By EDGAR

Jay E. Ingram, Legal Branch Chief

Division of Corporation Finance

U.S. Securities and Exchange Commission

Mail Stop 4631

100 F Street, N.E.

Washington, D.C. 20549-4631

Re:	Dogness (International) Corporation
	Registration Statement on Form F-1
	File No.:  333-220547

Dear Mr. Ingram:

Pursuant to Rule 461 under the Securities Act of 1933, the undersigned, as placement agent of the proposed issuer, hereby joins the request of Dogness (International) Corporation that the effective date of the above-referenced Registration Statement on Form F-1 be declared effective at 3:30 p.m. (Eastern Standard Time) on December 7, 2017, or as soon as practicable thereafter. 

Sincerely,

Spartan Securities Group, Ltd.

/s/ David Lopez 

Name: David Lopez

Title: CCO

Date: December 5, 2017