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SEC Comment Letter for CHINA PHARMA HOLDINGS, INC. (CPHI) (CIK 0001106644) (CPHI) — Aug 19, 2005

CHINA PHARMA HOLDINGS, INC. (CPHI) (CIK 0001106644)
Date: Aug. 19, 2005 · CIK: 0001106644 · Accession: 0000000000-05-042952

AI Filing Summary & Sentiment

Date
August 19, 2005
Author
Patricia Armelin
Form
UPLOAD
Company
CHINA PHARMA HOLDINGS, INC. (CPHI) (CIK 0001106644)

Letter

Mail Stop 7010 August 19, 2005 Mr. Timothy P. Halter TS Electronics 12890 Hilltop Road Argyle, Texas 76226

RE: TS Electronics Form 8-K Item 4.01 Filed August 18, 2005 File No. 0-29523

Dear Mr. Halter:

We have reviewed your filings and have the following comments. Where indicated, we think you should revise your documents 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 supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not 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 on any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter.

1. Please advise us about the following:

- We were unable to confirm that your independent accountant, Hansen, Barnett & Maxwell, PC is currently licensed in Texas. - We assume that the operations and assets of your company are located in Texas. Tell us why you selected a Utah accounting firm to perform your audit. - Tell us if the audit will be performed in Texas or Utah. - Tell us how you have met those requirements to provide financial statements audited by an auditor who meets the requirements of Rule 2- 01(a) of Regulation S-X. - Tell us what consideration you have given to Texas state laws governing audits of Texas companies performed by accountants who are licensed by other states.

*****

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require. 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 filings; * staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff 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.

Please file your supplemental response via EDGAR in response to these comments within 5 business days of the date of this letter. Please note that if you require longer than 5 business days to respond, you should contact the staff immediately to request additional time. You may wish to provide us with marked copies of each amended filing to expedite our review. Direct any questions regarding the above to the undersigned at (202) 551-3747.

Sincerely,
Patricia Armelin
Staff Accountant
??

Show Raw Text
<DOCUMENT>
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<TEXT>

Mail Stop 7010

	August 19, 2005

Mr. Timothy P. Halter
TS Electronics
12890 Hilltop Road
Argyle, Texas 76226

	RE:  	TS Electronics
		Form 8-K Item 4.01
		Filed August 18, 2005
		File No. 0-29523

Dear Mr. Halter:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your documents 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 supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not 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 on any other aspect
of
our review.  Feel free to call us at the telephone number listed
at
the end of this letter.

1. Please advise us about the following:

- We were unable to confirm that your independent accountant,
Hansen,
Barnett & Maxwell, PC is currently licensed in Texas.
- We assume that the operations and assets of your company are
located
in Texas. Tell us why you selected a Utah accounting firm to
perform
your audit.
- Tell us if the audit will be performed in Texas or Utah.
- Tell us how you have met those requirements to provide financial
statements audited by an auditor who meets the requirements of
Rule 2-
01(a) of Regulation S-X.
- Tell us what consideration you have given to Texas state laws
governing audits of Texas companies performed by accountants who
are
licensed by other states.

*****

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

      Please file your supplemental response via EDGAR in response
to
these comments within 5 business days of the date of this letter.
Please note that if you require longer than 5 business days to
respond, you should contact the staff immediately to request
additional time.  You may wish to provide us with marked copies of
each amended filing to expedite our review.  Direct any questions
regarding the above to the undersigned at (202) 551-3747.

							Sincerely,

								Patricia Armelin
								Staff Accountant
??

??

??

??

Mr. Timothy P. Halter
TS Electronics
August 19, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>