SEC Company Response from Kuber Resources Corp (KUBR) (CIK 0001081834) (KUBR) — Aug 27, 2008
Kuber Resources Corp (KUBR) (CIK 0001081834)
Date: Aug. 27, 2008 · CIK: 0001081834 · Accession: 0001356018-08-000566
AI Filing Summary & Sentiment
File numbers found in text: 000-26119
Referenced dates: August 14, 2008
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CORRESP
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filename1.htm
uonlcorresp.htm
UONLIVE
CORPORATION
5/F,
Guangdong Finance Building
88
Connaught Road West
Hong
Kong
SAR of
the People’s Republic of China
August
27, 2008
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
100 F
Street, N.E.
Mail Stop
4561
Washington,
D. C. 20549-7010
ATTN: Christine
Davis
Assistant Chief Accountant
Re: China
World Trade Corporation
Form
10-KSB/A for Fiscal Year Ended December 31, 2007
Filed
August 5, 2008
File No.
000-26119
Ladies
and Gentlemen:
Thank you
for your comment letter dated August 14, 2008 (the “Comment Letter”), with
respect to the above-captioned Form 10-KSB/A for fiscal year ended December 31,
2007. Our amended Form 10-KSB/A of Uonlive Corporation (f/k/a China
World Trade Corporation), a Nevada corporation (the “Company”) incorporates our
responses to your comments, and this letter sets forth each of your comments
with our responses below.
Form 10-KSB/A for Fiscal
Year Ended December 31, 2007
Item 8A. Controls and
Procedures
1.
We
note that in your amended Form 10-KSB your management has again concluded
that disclosure controls 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 designed 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 reporting, 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 the fiscal
year. Please further amend the Form 10-KSB to disclose
management’s revised conclusion on the effectiveness of your disclosure
controls and procedures as of the end of the fiscal year. If
you continue to believe that your disclosure controls and procedures are
effective, please tell us the factors you considered and highlight for us
those factors that supported your
conclusion.
Response 1: In
retrospect, our current management has concluded that our disclosure
controls and procedures and internal control over financial reporting were
not effective for the fiscal year ended December 31, 2007, as the Staff
pointed out. Therefore, we have revised Item 8A and Item 8AT to
indicate that our disclosure controls and procedures and internal control
over financial reporting were not effective as of December 31,
2007.
2.
We
note your statement that there have been no changes in your internal
controls over financial reporting “known to [y]our chief executive officer
and chief financial officer” during your last fiscal quarter that have
materially affected, or is reasonably likely to materially 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 reporting during your last
fiscal quarter, and revise your disclosure to remove the phrase “known to
our chief executive officer and chief financial
officer.” Similar concerns apply to your Form 10-Q for the
fiscal quarter ended March 31, 2008 and June 30,
2008.
Response 2: We confirm
that there have been no changes in our internal control over financial
reporting during our last fiscal quarter for the year ended December 31,
2007 and for the quarters ended March 31, 2008 and June 30,
2008. We have revised the disclosure in our Form 10-KSB/A2 to
delete the phrase “known to our chief executive officer and chief
financial officer” and will be sure that all future periodic filings
contain a definitive conclusion by management regarding internal control
over financial reporting, as required in Item 308(c) of Regulation
S-B.
We
acknowledge that:
·
The
company is responsible for the adequacy and accuracy of the disclosure in
the filings;
·
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
·
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.
Please
let us know if you have any further questions. We would appreciate if
you would advise us at your earliest convenience if any further changes may be
necessary to our filings.
Sincerely,
/s/
Cheung Chi Ho
Cheung
Chi Ho
Chief
Executive Officer
cc: Harold
H. Martin, Esq.
Enclosures
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