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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

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 000-26119

Referenced dates: August 5, 2008

Date
August 14, 2008
Author
Not clearly detected
Form
UPLOAD
Company
Kuber Resources Corp (KUBR) (CIK 0001081834)

Letter

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

Show Raw Text
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