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SEC Company Response from CHINA TECHNOLOGY GLOBAL CORP (CIK 0001021126) — May 5, 2005

CHINA TECHNOLOGY GLOBAL CORP (CIK 0001021126)
Date: May 5, 2005 · CIK: 0001021126 · Accession: 0000949353-05-000178

AI Filing Summary & Sentiment

File numbers found in text: 000-21919

Date
March 31, 2004
Author
Corporate Secretary
Form
CORRESP
Company
CHINA TECHNOLOGY GLOBAL CORP (CIK 0001021126)

Letter

29 April 2005 United States Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549-0405 For the attention of Mr. Yong Choi

RE: Form 20-F for the fiscal year ended March 31, 2004 China Technology Global Corporation FILE NO. 000-21919

Dear Mr. Choi,

I refer to your letter dated 2 March 2005 and would like to thank you again for your patient of our delayed response and your efforts in enhancing our overall disclosure in Form 20F reporting.

Having taken into the measures of your valuable advices, we have reviewed our filings and would like to make the below recommendations for your kind consideration.

1. Net Loss, Page 24 & 25

In our Form 20-F filed on 18 November 2004, "Loss on disposal of fixed assets" and "Fixed asset provision for the potential decline in value of two unfinished paper mills and idle machineries in plant at Conghua" made during the reporting year were classified as non-recurring items. It is because the Company had made a one-off decision and disposed of all of its paper business related fixed assets during the year and the Company believed there would unlikely be any further disposal of paper business related fixed assets in the coming years. As such, the Management considered that it would be appropriate to classify those items as non-recurring items and would not recommend amendments to the filing. However, if the SEC staff considers the items should be treated as recurring items, we would propose to amend the presentation in the future filings (i.e. Form 20F filing for the financial year ended March 31,

<PAGE>

2005) based on the fact that there is no material changes to the numbers nor overall disclosure of the previous filing.

2. Consolidation Statements of Operations, Page 50

In our Form 20F, we had included "Loss on disposal of fixed assets", "Provision for doubtful debts" and "Impairment losses of property, plant and equipment" into Statements of Operations on Page 50 and we believed they were all included into "Loss from Operations" and not being excluded from "Loss from Operations". In fact, the Company did not present a subtotal Loss from Operations in its filing. For better understanding of the nature and effect of the expenses, we had shown the items separately in the Statements of Operations. By showing the items separately, we believe the readers are being provided with additional valuable information in evaluating the performance of the Company. Again, we do not recommend amendments to the filing and should the SEC staff considers that an amendment is needed, we would propose to amend the presentation in the future filings.

3. Note 15 - Loss on Disposal of Subsidiaries, Page 67

Our board of directors devoted its time and efforts to appraising the value of our assets and the merits of the business plan under which we have operated for the past several years. After their review, we determined that it was not feasible to continue to purse the earlier objective of building an integrated paper manufacture with four principal paper plants. As such we entered into an agreement to dispose of our paper business subsidiaries and fixed assets for a total consideration of HK5.00 based on an arms length negotiation with an unrelated party. Pursuant to the agreement, we have only leased back certain of the fixed assets and maintained limited lines of paper operation. The term of the lease is only one year and renewable yearly because the directors are not optimistic of the long term profitability of the paper business. In view of the rising costs of the operation and the difficulty of generating profit in the future, the directors believe the nominal value of consideration received is reasonable. The directors also believe it would not be appropriate to consider the lease term is favorable when those leaseback assets are unlikely to generate future income to the Company. As a matter of fact, the Company has ceased all its paper business in the first quarter 2005 due to the unexpected poor performance of its paper business environment of China and all leased assets have been returned to the owner and the lease term has ended in March 2005.

Details of computation of sale of fixed assets :

<PAGE>

HK$'000 Proceeds on sale of fixed assets (HK$5) - Net book value 19,500 --------- Loss on sale of fixed assets (19,500) =========

The Company acknowledges that:

o the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

o staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and

o the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We trust the above shall resolve your queries and should you have any questions, please do not hesitate to contact the undersigned at (Office) 852-2255-0639.

Yours sincerely, For and on behalf of China Technology Global Corporation

/s/ YU Wai Kit

YU Wai Kit (Eddie) Corporate Secretary

Show Raw Text
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By fax: (202) 942-9528 and by post

29 April 2005

United States
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0405

For the attention of Mr. Yong Choi

RE:     Form 20-F for the fiscal year ended March 31, 2004
        China Technology Global Corporation
        FILE NO. 000-21919

Dear Mr. Choi,

I refer to your letter  dated 2 March 2005 and would like to thank you again for
your patient of our delayed  response and your efforts in enhancing  our overall
disclosure in Form 20F reporting.

Having taken into the measures of your  valuable  advices,  we have reviewed our
filings  and  would  like  to make  the  below  recommendations  for  your  kind
consideration.

1. Net Loss, Page 24 & 25

In our Form 20-F filed on 18 November  2004,  "Loss on disposal of fixed assets"
and "Fixed asset provision for the potential  decline in value of two unfinished
paper mills and idle  machineries in plant at Conghua" made during the reporting
year were classified as non-recurring  items. It is because the Company had made
a one-off  decision  and  disposed of all of its paper  business  related  fixed
assets  during the year and the Company  believed  there  would  unlikely be any
further  disposal of paper business related fixed assets in the coming years. As
such, the Management  considered  that it would be appropriate to classify those
items as non-recurring  items and would not recommend  amendments to the filing.
However,  if the SEC staff  considers  the items  should be treated as recurring
items,  we would propose to amend the  presentation  in the future filings (i.e.
Form 20F filing for the  financial  year ended March 31,

<PAGE>

2005)  based on the fact that there is no  material  changes to the  numbers nor
overall disclosure of the previous filing.

2. Consolidation Statements of Operations, Page 50

In our Form 20F, we had included "Loss on disposal of fixed assets",  "Provision
for doubtful  debts" and  "Impairment  losses of property,  plant and equipment"
into  Statements of Operations on Page 50 and we believed they were all included
into "Loss from Operations" and not being excluded from "Loss from  Operations".
In fact,  the  Company did not present a subtotal  Loss from  Operations  in its
filing.  For better  understanding of the nature and effect of the expenses,  we
had shown the items  separately in the Statements of Operations.  By showing the
items  separately,  we believe the readers are being  provided  with  additional
valuable information in evaluating the performance of the Company.  Again, we do
not recommend  amendments to the filing and should the SEC staff  considers that
an amendment is needed, we would propose to amend the presentation in the future
filings.

3.    Note 15 - Loss on Disposal of Subsidiaries, Page 67

Our board of directors  devoted its time and efforts to appraising  the value of
our assets and the merits of the business  plan under which we have operated for
the past  several  years.  After their  review,  we  determined  that it was not
feasible to continue to purse the earlier  objective  of building an  integrated
paper  manufacture with four principal paper plants.  As such we entered into an
agreement to dispose of our paper business  subsidiaries  and fixed assets for a
total  consideration  of  HK5.00  based on an arms  length  negotiation  with an
unrelated party. Pursuant to the agreement,  we have only leased back certain of
the fixed assets and maintained  limited lines of paper  operation.  The term of
the lease is only one year and  renewable  yearly  because the directors are not
optimistic of the long term profitability of the paper business.  In view of the
rising costs of the  operation and the  difficulty  of generating  profit in the
future,  the directors  believe the nominal value of  consideration  received is
reasonable.  The directors  also believe it would not be appropriate to consider
the lease term is favorable when those leaseback assets are unlikely to generate
future  income to the Company.  As a matter of fact,  the Company has ceased all
its  paper  business  in the  first  quarter  2005  due to the  unexpected  poor
performance  of its paper  business  environment  of China and all leased assets
have been returned to the owner and the lease term has ended in March 2005.

Details of computation of sale of fixed assets :

<PAGE>

                                                HK$'000
Proceeds on sale of fixed assets (HK$5)               -
Net book value                                   19,500
                                               ---------
Loss on sale of fixed assets                    (19,500)
                                               =========

The Company acknowledges that:

o    the  Company is responsible for the adequacy and accuracy of the disclosure
     in the filings;

o    staff  comments  or changes to disclosure in response to staff  comments do
     not foreclose the  Commission  from  taking  any action with respect to the
     filings; and

o    the  Company may  not assert staff  comments as a defense in any proceeding
     initiated by the Commission or any person under the federal securities laws
     of the United States.

We trust the above shall resolve your queries and should you have any questions,
please do not hesitate to contact the undersigned at (Office) 852-2255-0639.

Yours sincerely,
For and on behalf of
China Technology Global Corporation

/s/ YU Wai Kit

YU Wai Kit (Eddie)
Corporate Secretary

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