SecProbe.io

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Mail Stop 6010

      August 4, 2005

Suk Joo Ko
Director of Accounting Team
Mirae Corporation
#9-2, Cha Am-Dong
Chun An, Chung Chong Nam-Do 330-200
Republic of Korea

	Re:	Mirae Corporation
		Form 20-F for the Year Ended December 31, 2004
		Filed June 30, 2005
      File No. 000-30376

Dear Mr. Suk Joo Ko:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  In some of our comments, 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 review 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.

Form 20-F for the Fiscal Year Ended December 31, 2004

Consolidated Balance Sheets, page F-5

1. We note your current liabilities include an allowance for loss
on
collateralized assets. You additionally disclose in Note 13 that
the
accrual was recorded "as the management believed that such
collateral
would probably be used to repay on behalf of Cyber Bank."  Please
tell us how U.S. GAAP would require you to account for
collateralized
assets and any impairment thereof, citing the appropriate
authoritative guidance. Revise Note 29 in future filings to
quantify
and disclose any GAAP differences in connection with this matter.
We
may have further comments after reviewing your response.

2. Summary of Significant Accounting Policies, page F-13

i. Equity Method of Accounting, page F-16

2. We see your disclosure that the "differences between the
acquisition cost and net asset value of the investee are amortized
over 20 years using the straight-line method."  Please tell us the
nature of the difference referenced in your disclosures and how
this
accounting policy differs from the U.S. GAAP equivalent, citing
the
applicable authoritative guidance. Additionally, please tell us
how
Note 29 quantifies and discloses any differences in generally
accepted accounting principles for this matter. We may have
further
comments after reviewing your response.  Revise future filings as
necessary based on our comment.

6. Equity Securities Accounted For Using the Equity Method, page
F-21

3. You disclose that during 2003, you acquired additional shares
of
Cyber Bank thereby increasing your ownership percentage to 28.25%.
We
note that prior to this increase in ownership, you accounted for
your
investment in Cyber Bank under U.S. GAAP as a cost method
investment.
Please show us how you accounted for the change from a cost method
investment to an equity method investee under U.S. GAAP and how
you
quantify and disclose any GAAP differences in Note 29. Please
refer
to paragraph 19(m) of APB 18.  Revise future filings as necessary
based on our comment.

4. In this regard, please provide us (in U.S. dollars and using US
GAAP amounts) the test of significance for the income and
investment
conditions set forth in Rule 1-02(w) of Regulation S-X for all
your
50% or less owned equity investments. Additionally, please tell us
how your financial statements and disclosures in Note 29 meet the
requirements of Rule 3-09 and Rule 4-08(g) of Regulation S-X.  We
may
have further comments after reviewing your response.  Revise
future
filings as necessary based on our comment.

Note 29. Reconcilliation to Accounting Principles Generally
Accepted
in the United States of America, F-38

t. New Accounting Pronouncements, page F-42

5. We note your disclosure that you hold a variable interest in
Cyber
Bank, but that you concluded you were not the primary beneficiary.
Please tell us how you assessed and concluded that you were not
the
primary beneficiary for purposes of FIN 46R.  Please reference the
applicable sections of FIN 46R you used to make your conclusions,
including the one that consolidation of Cyber Bank was not
required.
We may have further comments after reviewing your response.

       As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 that they have provided all information
investors require for an informed decision.  Since the company and
its management are in possession of all facts relating 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 comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Kevin Kuhar, Staff Accountant, at (202) 551-
3662 or me at (202) 551-3603 if you have questions regarding these
comments on the financial statements and related matters.  In this
regard, do not hesitate to contact Angela Crane, Branch Chief, at
(202) 551-3554.

								Sincerely,

								Jay Webb
								Reviewing Accountant

Suk Joo Ko
Mirae Corporation
August 4, 2005
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