SEC Comment Letter for GIVBUX, INC. (GBUX) (CIK 0001169138) (GBUX) — Apr 11, 2008
GIVBUX, INC. (GBUX) (CIK 0001169138)
Date: April 11, 2008 · CIK: 0001169138 · Accession: 0000000000-08-019034
AI Filing Summary & Sentiment
Referenced dates: January 29, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE March 17, 2008 Mr. Qin Long Chief Executive Officer, Rub A Dub Soap, Inc. No. 177, Chenyang Section 308 National Highway Danshan Industrial Area Qindao, China 266109 Re: Rub A Dub Soap, Inc. Form 10-KSB for the fiscal year ended May 31, 2007 Form 8-K filed November 14, 2007 File No. 0-52142
Dear Mr. Long: We have reviewed your response to our letter dated January 29, 2008 and have the following comment. We ask that you respond by March 31, 2008 Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requir ements 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 aspe ct of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 8-K filed November 14, 2007
Financial Statements General
1. We have reviewed your response to our prio r comment number two from our letter dated January 29, 2008. Please clarify for us if the acquired subsidiaries operated under common control in all financia l periods presented prior to their acquisition in August 2007. If the subsidiaries did not operate unde r common control, please tell us why you believe it is appropriate to present their results on a combined basis.
Mr. Qin Long Rub A Dub Soap, Inc. March 17, 2008 Page 2
As appropriate, please amend your filing a nd respond to these comments within 10 business days or tell us when you will provide us with a response. Please provide us with a supplemental response letter that keys your re sponses to our comments and provides any requested supplemental information. Detailed letter s greatly facilitate our review. Please file your supplemental response on EDGAR as a corres pondence file. Please understand that we may have additional comments after reviewing your responses to our comments. If you have any questions regarding these comments, please direct them to Mindy Hooker, Staff Accountant, at (202) 551-3732, Tricia Armelin, St aff Accountant, at (202) 551- 3747 or to the undersigned at (202) 551-3768. Sincerely, John Cash Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
March 17, 2008
Mr. Qin Long Chief Executive Officer, Rub A Dub Soap, Inc. No. 177, Chenyang Section 308 National Highway Danshan Industrial Area Qindao, China 266109
Re: Rub A Dub Soap, Inc.
Form 10-KSB for the fiscal year ended May 31, 2007
Form 8-K filed November 14, 2007
File No. 0-52142
Dear Mr. Long:
We have reviewed your response to our letter dated January 29, 2008 and have the
following comment. We ask that you respond by March 31, 2008
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements 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 aspe ct of our review. Feel free to call us at
the telephone numbers listed at the end of this letter.
Form 8-K filed November 14, 2007
Financial Statements
General
1. We have reviewed your response to our prio r comment number two from our letter dated
January 29, 2008. Please clarify for us if the acquired subsidiaries operated under
common control in all financia l periods presented prior to their acquisition in August
2007. If the subsidiaries did not operate unde r common control, please tell us why you
believe it is appropriate to present their results on a combined basis.
Mr. Qin Long
Rub A Dub Soap, Inc.
March 17, 2008 Page 2
As appropriate, please amend your filing a nd respond to these comments within 10
business days or tell us when you will provide us with a response. Please provide us with a
supplemental response letter that keys your re sponses to our comments and provides any
requested supplemental information. Detailed letter s greatly facilitate our review. Please file
your supplemental response on EDGAR as a corres pondence file. Please understand that we
may have additional comments after reviewing your responses to our comments.
If you have any questions regarding these comments, please direct them to Mindy
Hooker, Staff Accountant, at (202) 551-3732, Tricia Armelin, St aff Accountant, at (202) 551-
3747 or to the undersigned at (202) 551-3768.
Sincerely, John Cash Branch Chief