SEC Comment Letter for GIVBUX, INC. (GBUX) (CIK 0001169138) (GBUX) — May 13, 2008
GIVBUX, INC. (GBUX) (CIK 0001169138)
Date: May 13, 2008 · CIK: 0001169138 · Accession: 0000000000-08-024383
AI Filing Summary & Sentiment
File numbers found in text: 000-52142
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010
DIVISION OF CORPORATION FINANCE
Mail Stop 7010 May 13, 2008 Qin Long Chief Executive Officer Rub A Dub Soap, Inc. No. 177 Chengyang Section 308 National Highway Danshan Industrial Area Qingdao, China 266109 Re: Rub A Dub Soap, Inc. Amendment No. 1 to Prelimin ary Information Statement On Schedule 14C Filed May 1, 2008 File No. 000-52142 Dear Mr. Long: We have limited our review of your filing to those issues we have addressed in our comments. We welcome any questions you ma y have about our comments or any other aspect of our review. Feel fr ee to call us at the telephone numbe rs listed at the end of this letter. General
1. We note that on October 26, 2007, Rub A D ub Soap, Inc., entered into a Stock Purchase Agreement with Zhongsen In ternational Company Group, Ltd., whereby Rub A Dub Soap acquired all of the issu ed and outstanding capital stock of Zhongsen from the Zhongsen shareholders in exchange for 96.5% shares of Rub A Dub Soap common stock, a reverse acquisiti on. If the transaction was required to be approved by shareholders, please explain why no proxy or information statement was filed prior to the conduct of the solicitation or taking of the corporate action.
* * * *
Please contact Jessica Kane at (202) 551-3235 or Craig Slivka at (202) 551-3729 with any questions.
Qin Long Rub A Dub Soap, Inc. May 13, 2008 Page 2 Sincerely,
Pamela Long Assistant Director cc: Scott Kline, Esq. Thelen Reid Brown Raysman & Steiner LLP 101 Second Street, Suite 1800 San Francisco, California 94105
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
Mail Stop 7010 May 13, 2008 Qin Long Chief Executive Officer Rub A Dub Soap, Inc. No. 177 Chengyang Section 308 National Highway Danshan Industrial Area Qingdao, China 266109
Re: Rub A Dub Soap, Inc.
Amendment No. 1 to Prelimin ary Information Statement
On Schedule 14C
Filed May 1, 2008 File No. 000-52142
Dear Mr. Long:
We have limited our review of your filing to those issues we have addressed in our
comments. We welcome any questions you ma y have about our comments or any other
aspect of our review. Feel fr ee to call us at the telephone numbe rs listed at the end of this
letter. General
1. We note that on October 26, 2007, Rub A D ub Soap, Inc., entered into a Stock
Purchase Agreement with Zhongsen In ternational Company Group, Ltd., whereby
Rub A Dub Soap acquired all of the issu ed and outstanding capital stock of
Zhongsen from the Zhongsen shareholders in exchange for 96.5% shares of Rub A Dub Soap common stock, a reverse acquisiti on. If the transaction was required
to be approved by shareholders, please explain why no proxy or information statement was filed prior to the conduct of the solicitation or taking of the corporate action.
* * * *
Please contact Jessica Kane at (202) 551-3235 or Craig Slivka at (202) 551-3729
with any questions.
Qin Long
Rub A Dub Soap, Inc. May 13, 2008 Page 2
Sincerely,
Pamela Long Assistant Director
cc: Scott Kline, Esq.
Thelen Reid Brown Raysman & Steiner LLP 101 Second Street, Suite 1800 San Francisco, California 94105