SEC Comment Letter for Kuber Resources Corp (KUBR) (CIK 0001081834) (KUBR) — Aug 15, 2008
Kuber Resources Corp (KUBR) (CIK 0001081834)
Date: Aug. 15, 2008 · CIK: 0001081834 · Accession: 0000000000-08-041249
AI Filing Summary & Sentiment
File numbers found in text: 000-26119
Referenced dates: August 5, 2008
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Mail Stop 4561
August 14, 2008
Mr. Cheung Chi Ho
Chief Executive Officer
Uonlive Corporation
(f/k/a China World Trade Corporation)
5/F, Guangdong Finance Building
88 Connaught Road West
Hong Kong
Re: China World Trade Corporation
Form 10-KSB/A for Fiscal Year Ended December 31, 2007
Filed August 5, 2008
File No. 000-26119
Dear Mr. Ho:
We have reviewed your response letter dated August 5, 2008 in connection with
the above-referenced filing and have the followi ng comments. If indicated, we think you
should revise your document in response to these comments. If you disagree, we will
consider your explanation as to why our comment is inapplicable or a revision is
unnecessary. Please be as deta iled as necessary in your explanation. In our comments,
we may ask you to provide us with suppl emental information so we may better
understand your disclosure. After reviewing th is information, we may raise additional
comments.
Form 10-KSB/A for Fiscal Year Ended December 31, 2007
Item 8A. Controls a nd Procedures, page 52
1. We note that in your amended Form 10-KSB your management has again
concluded that disclosure c ontrols and procedures were effective as of the end of
the fiscal year. Disclosure controls and procedures include, “controls and
procedures of an issuer that are designe d to ensure that information required to
be disclosed by the issuer in the reports that it files or submits under the Act is
recorded, processed, summarized and reported, within the time periods specified in the Commission’s rules and forms.” Considering management's failure to provide its report on internal control over financial report ing, it is unclear to us
how you are able to continue to conclude that your disclosure controls and
procedure are effective as of the end of th e fiscal year. Please further amend the
Form 10-KSB to disclose management's revised conclusion on the effectiveness
Mr. Chueng Chi Ho
Uonlive Corporation
(f/k/a China World Trade Corporation)
August 14, 2008 Page 2
of your disclosure controls and procedures as of the end of the fiscal year. If
you continue to believe that your disc losure controls and procedures are
effective, please tell us the factors you considered and highlight for us those
factors that supporte d your conclusion.
2. We note your statement that there have been no changes in your internal controls over financial repor ting “known to [y]our chief executive officer and
chief financial officer” duri ng your last fiscal quarte r that have materially
affected, or is reasonably likely to materi ally affect, your internal control over
financial reporting. Item 308(c) of Regulation S-B requires a definitive
conclusion by your management regarding changes in internal control over financial reporting. Please confirm, if true, that there have been no changes in
your internal control over financial repor ting during your last fiscal quarter, and
revise your disclosure to remove the phrase “known to our chief executive
officer and chief financial officer.” Si milar concerns apply to your Form 10-Q
for the fiscal quarter ended March 31, 2008 and June 30, 2008.
* * * * * * *
Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T. If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review. Please furnish a cover letter that keys your response 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 any
amendment and your response to our comments.
You may contact Mark Sh annon, Staff Accountant, at (202) 551-3299 or me at
(202) 551-3408 if you have any questions regarding the above comments.
S i n c e r e l y ,
C h r i s t i n e D a v i s
Assistant Chief Accountant