SEC Comment Letter for CHINA YUCHAI INTERNATIONAL (CYD) — Jun 10, 2007
CHINA YUCHAI INTERNATIONAL LTD
Date: June 10, 2007 · CIK: 0000932695 · Accession: 0000000000-07-028466
AI Filing Summary & Sentiment
Referenced dates: August 4, 2006
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-5546 DIVISION OF CORPORATION FINANCE Mail Stop 5546 September 27, 2006 Via Facsimile (65) 6226 0502 and US Mail Philip Ting Sii Tien Chief Financial Officer China Yuchai International Limited 16 Raffles Quay #26-00 Hong Leong Building Singapore 048581
Re: China Yuchai International Limited Form 20-F Filed July 15, 2005 Response Letters Dated August 4, 2006 and September 7, File No. 1-13522
Dear Mr. Tien:
We have reviewed your response dated September 7, 2006 and have the following comment. Please be as detailed as necessary in your response. After reviewing this information, we may raise additional comments.
General
1. We note your response to prior comment two. Please confirm, if true, that Xinfei conducts its North Korean operations independent of you and your employees, and that Xinfei`s North Korean expenses and revenues do not affect your expenses and revenues. If, however, you or your subsidiaries` operations are affected by Xinfei`s North Korean operations, please discuss such overlapping or interrelated operations and expand your materiality analysis to take into account the North Korean contacts. For example, if you or your subsidiaries` operations are affected by Xinfei`s North Korean operations, express revenues from those operations as a percentage of your own total sales revenues, instead of as a percentage of Xinfei`s total sales revenues, and identify the significant factors underlying your conclusion that such North Korean contacts are qualitatively immaterial.
Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please contact James Lopez at (202) 551- 3536 if you have any questions about the comments or our review. You may also contact me at (202) 551-3470.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
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<FILENAME>filename1.txt
<TEXT>
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546
DIVISION OF
CORPORATION FINANCE
Mail Stop 5546
September 27, 2006
Via Facsimile (65) 6226 0502 and US Mail
Philip Ting Sii Tien
Chief Financial Officer
China Yuchai International Limited
16 Raffles Quay #26-00
Hong Leong Building
Singapore 048581
Re: China Yuchai International Limited
Form 20-F
Filed July 15, 2005
Response Letters Dated August 4, 2006 and September 7,
2006
File No. 1-13522
Dear Mr. Tien:
We have reviewed your response dated September 7, 2006 and
have
the following comment. Please be as detailed as necessary in your
response. After reviewing this information, we may raise
additional
comments.
General
1. We note your response to prior comment two. Please confirm, if
true, that Xinfei conducts its North Korean operations independent
of
you and your employees, and that Xinfei`s North Korean expenses
and
revenues do not affect your expenses and revenues. If, however,
you
or your subsidiaries` operations are affected by Xinfei`s North
Korean operations, please discuss such overlapping or interrelated
operations and expand your materiality analysis to take into
account
the North Korean contacts. For example, if you or your
subsidiaries`
operations are affected by Xinfei`s North Korean operations,
express
revenues from those operations as a percentage of your own total
sales revenues, instead of as a percentage of Xinfei`s total sales
revenues, and identify the significant factors underlying your
conclusion that such North Korean contacts are qualitatively
immaterial.
Please respond to this comment within 10 business days or
tell
us when you will provide us with a response. Please file your
response letter on EDGAR. Please contact James Lopez at (202)
551-
3536 if you have any questions about the comments or our review.
You
may also contact me at (202) 551-3470.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Peggy Fisher
Assistant Director
Division of Corporation Finance
Philip Ting Sii Tien
China Yuchai International Limited
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