SEC Comment Letter for CHINA YUCHAI INTERNATIONAL (CYD) — Oct 28, 2009
CHINA YUCHAI INTERNATIONAL LTD
Date: Oct. 28, 2009 · CIK: 0000932695 · Accession: 0000000000-09-060984
AI Filing Summary & Sentiment
File numbers found in text: 001-13522
Referenced dates: October 2, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE Mail Stop 3030 October 28, 2009 Hoh Weng Ming 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 for the fiscal year ended December 31, 2008 Filed April 8, 2009 File No. 001-13522
Dear Mr. Ming: We have reviewed your letter dated October 2, 2009 and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. After revi ewing this information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. 1. We note paragraph (b) of your response to comment 1. Please expand your response to discuss and apply the applicable legal standard to your facts, showing appropriate calculations, rath er than merely stating that you are in compliance with the Rule.
* * * As appropriate, please respond to these co mments within 10 business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewin g your response to our comment.
Hoh Weng Ming China Yuchai International Limited October 28, 2009 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. You may contact Gary Todd at (202) 551-3605 if you have questions regarding comments on the financial statements and related matters. Please contact Gabriel Eckstein at (202) 551-3286 or me at (202) 551-3314 with any other questions.
Sincerely,
Daniel Morris
S p e c i a l C o u n s e l
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
Mail Stop 3030
October 28, 2009 Hoh Weng Ming 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 for the fiscal year ended December 31, 2008
Filed April 8, 2009 File No. 001-13522
Dear Mr. Ming:
We have reviewed your letter dated October 2, 2009 and have the following
comment. In our comment, we may ask you to provide us with information so we may
better understand your disclosure. After revi ewing this information, we may raise
additional comments. Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
1. We note paragraph (b) of your response to comment 1. Please expand your
response to discuss and apply the applicable legal standard to your facts, showing
appropriate calculations, rath er than merely stating that you are in compliance
with the Rule.
* * *
As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response. Please understand that we may have additional comments after reviewin g your response to our comment.
Hoh Weng Ming
China Yuchai International Limited October 28, 2009 Page 2 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision. Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
You may contact Gary Todd at (202) 551-3605 if you have questions regarding
comments on the financial statements and related matters. Please contact Gabriel Eckstein at (202) 551-3286 or me at (202) 551-3314 with any other questions.
Sincerely,
Daniel Morris
S p e c i a l C o u n s e l