SEC Comment Letter for Kuber Resources Corp (KUBR) (CIK 0001081834) (KUBR) — Jun 29, 2007
Kuber Resources Corp (KUBR) (CIK 0001081834)
Date: June 29, 2007 · CIK: 0001081834 · Accession: 0000000000-07-031964
AI Filing Summary & Sentiment
Reasoning
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE Mail Stop 4561 June 28, 2007 William Tsang, Chairman China World Trade Corporation 3rd Floor, Goldlion Digital Network Center 138 Tiyu Road East, Tianhe Guangzhou, The People’s Republic of China
Re: China World Trade Corporation Preliminary Proxy Statement on Schedule 14A Filed June 19, 2007 File No. 0-26119
Dear Mr. Tsang:
We have limited our review of your filing to those issues we have addressed in our comments. Where indicated, we think you should revise your document in response to these comments. If you disagree, we w ill consider your explanation as to why our comment is inapplicable or a revision is unneces sary. Please be as detailed as necessary in your explanation. In some of our comme nts, we may ask you to provide us with information so we may better understand your disclosure. After reviewing 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 comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General
1. Please provide a separate vote for ea ch separate matter on the proxy card pursuant to Rule 14a-4(b)(1) of the proxy rules, which states that the proxy shall afford investors the opportunity to specify a choice between approval, disapproval of, or abstention with respect to each separate matter intended to be acted upon.
2. Please revise the proxy statement to disclose the reasons for seeking shareholder approval of the company’s annual report on Form 10-KSB. Also,
Morton Fleischer, Chie f Executive Officer China World Trade Corporation June 28, 2007 Page 2 please explain the effects to the compa ny, if any, if the annual report is not approved by its shareholders.
* * * * *
As appropriate, please amend your filing and respond to these comments within 10 business days or tell us when you will provid e us with a response. You may wish to provide us with marked copies of the amendm ent to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed co ver letters greatly faci litate our review. Please understand that we may have addi tional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsi ble for the accuracy an d 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.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comme nts as a defense in any proceeding initiated by the Commission or any person under the federal secu rities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing.
You may contact Uyen Tran at (202) 551-5315 with any questions.
S i n c e r e l y ,
K a r e n J . G a r n e t t Assistant Director
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
Mail Stop 4561
June 28, 2007
William Tsang, Chairman
China World Trade Corporation
3rd Floor, Goldlion Digital Network Center
138 Tiyu Road East, Tianhe
Guangzhou, The People’s Republic of China
Re: China World Trade Corporation
Preliminary Proxy Statement on Schedule 14A
Filed June 19, 2007
File No. 0-26119
Dear Mr. Tsang:
We have limited our review of your filing to those issues we have addressed in
our comments. Where indicated, we think you should revise your document in response
to these comments. If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary. Please be as detailed as necessary
in your explanation. In some of our comme nts, we may ask you to provide us with
information so we may better understand your disclosure. After reviewing 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 comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
General
1. Please provide a separate vote for ea ch separate matter on the proxy card
pursuant to Rule 14a-4(b)(1) of the proxy rules, which states that the proxy
shall afford investors the opportunity to specify a choice between approval,
disapproval of, or abstention with respect to each separate matter intended to
be acted upon.
2. Please revise the proxy statement to disclose the reasons for seeking
shareholder approval of the company’s annual report on Form 10-KSB. Also,
Morton Fleischer, Chie f Executive Officer
China World Trade Corporation
June 28, 2007
Page 2
please explain the effects to the compa ny, if any, if the annual report is not
approved by its shareholders.
* * * * *
As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response. You may wish to
provide us with marked copies of the amendm ent to expedite our review. Please furnish
a cover letter with your amendment that keys your responses to our comments and
provides any requested information. Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.
We urge all persons who are responsi ble for the accuracy an d 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.
In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Uyen Tran at (202) 551-5315 with any questions.
S i n c e r e l y ,
K a r e n J . G a r n e t t
Assistant Director