SecProbe.io

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Mail Stop 6010

      November 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 Fiscal Year Ended December 31, 2004
		Filed June 30, 2005
      File No. 000-30376

Dear Mr. Suk Joo Ko:

      We have reviewed your response letter dated October 13, 2005
and subsequent filings and have the following additional comments.
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 will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  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 Sheet, page F-5

1. Please refer to prior comment 1 of our letter dated August 4,
2005.  It is still not clear to us what the current liability line
item "allowance for loss on collateralized assets" is and whether
it
is appropriate and required under U.S. generally accepted
accounting
principles.  Please tell us more about this liability and revise
Note
29 in future filings to quantify and disclose any GAAP differences
related thereto.  We may have further comments after reviewing
your
response.

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

t. New Accounting Pronouncements, page F-42

2. Please refer to prior comment 5 of our letter dated August 4,
2005.  We note your response and may have further comments after
reviewing changes to your filed amendment that result from our
prior
comment.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment 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 cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and 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 and 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.

      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
November 4, 2005
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