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SEC Comment Letter for Smart Powerr Corp. (CREG) (CIK 0000721693) (CREG) — Feb 28, 2011

Smart Powerr Corp. (CREG) (CIK 0000721693)
Date: Feb. 28, 2011 · CIK: 0000721693 · Accession: 0000000000-11-012791

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Summary

Reasoning

Referenced dates: February 9, 2011

Date
February 28, 2011
Author
William H. Thompson
Form
UPLOAD
Company
Smart Powerr Corp. (CREG) (CIK 0000721693)

Letter

February 28, 2011 Guohua Ku Chief Executive Officer China Recycling Energy Corporation 12/F, Tower A, Chang An International Building No. 88 Nan Guan Zheng Jie Xi An City, Shan Xi Province, China 710068

Re: China Recycling Energy Corporation Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 16, 2010 File No. 1-34625

Dear Mr. Ku: We have reviewed your response letter date d February 24, 2011 and have the following comment. In our comment, we may ask you to pr ovide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comment applies to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2009

Item 8. Financial Statements and Supplementary Data, page 26

Consolidated Statements of Cash Flows, page 30

1. We reviewed the revised consolidated statem ents of cash flows provided in response to comment one in our letter dated February 9, 2011. Please provide us with a reconciliation of the changes in the “Investment in sales type leases, net,” and “Construction in progress” bala nce sheet line items to the “Changes in gross sales type leases receivables,” Collection of principal on sales type leases,” and “Construction in progress” reported in the statem ent for each year presented.

Guohua Ku China Recycling Energy Corporation February 28, 2011 Page 2

You may contact Adam Phippen at (202) 551- 3336 if you have any questions. In his absence you may contact me at (202) 551-3344. Sincerely, /s/ William H. Thompson

William H. Thompson A c c o u n t i n g B r a n c h C h i e f

Show Raw Text
February 28, 2011
 Guohua Ku Chief Executive Officer China Recycling Energy Corporation 12/F, Tower A, Chang An International Building No. 88 Nan Guan Zheng Jie Xi An City, Shan Xi Province, China 710068

Re:  China Recycling Energy Corporation
Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 16, 2010 File No. 1-34625

Dear Mr. Ku:
We have reviewed your response letter date d February 24, 2011 and have the following
comment.  In our comment, we may ask you to pr ovide us with information so we may better
understand your disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.
 Form 10-K for Fiscal Year Ended December 31, 2009

 Item 8.  Financial Statements and Supplementary Data, page 26

 Consolidated Statements of Cash Flows, page 30

 1. We reviewed the revised consolidated statem ents of cash flows provided in response to
comment one in our letter  dated February 9, 2011.  Please provide us with a
reconciliation of the changes in the “Investment in sales type leases, net,” and
“Construction in progress” bala nce sheet line items to the “Changes in gross sales type
leases receivables,” Collection of principal on sales type leases,”  and “Construction in
progress” reported in the statem ent for each year presented.

Guohua Ku
China Recycling Energy Corporation February 28, 2011 Page 2

 You may contact Adam Phippen at (202) 551- 3336 if you have any questions.  In his
absence you may contact me at (202) 551-3344.
Sincerely,  /s/ William H. Thompson

William H. Thompson
        A c c o u n t i n g  B r a n c h  C h i e f