SEC Comment Letter for GIVBUX, INC. (GBUX) (CIK 0001169138) (GBUX) — May 15, 2008
GIVBUX, INC. (GBUX) (CIK 0001169138)
Date: May 15, 2008 · CIK: 0001169138 · Accession: 0000000000-08-024976
AI Filing Summary & Sentiment
Referenced dates: March 17, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE May 15, 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 8-K filed November 14, 2007 File No. 0-52142
Dear Mr. Long: We have reviewed your response to ou r letter dated March 17, 2008 and have the following comment. We ask that you respond by May 29, 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 note your response to our prior comment one from our letter dated March 17, 2008 and your related disclosures on page 17 of your Form 10-Q for the period ended March 31, 2008 that the acquired subsidiaries operate under common control because they all have the same key management members. Plea se confirm for us, if true, that the voting ownership meets the criteria for common contro l in all financial periods presented prior to the August 2007 acquisitions. Reference paragraph 3 of EITF 02-5.
Mr. Qin Long Rub A Dub Soap, Inc. May 15, 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. Plea se 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
May 15, 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 8-K filed November 14, 2007
File No. 0-52142
Dear Mr. Long:
We have reviewed your response to ou r letter dated March 17, 2008 and have the
following comment. We ask that you respond by May 29, 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 note your response to our prior comment one from our letter dated March 17, 2008
and your related disclosures on page 17 of your Form 10-Q for the period ended March
31, 2008 that the acquired subsidiaries operate under common control because they all
have the same key management members. Plea se confirm for us, if true, that the voting
ownership meets the criteria for common contro l in all financial periods presented prior
to the August 2007 acquisitions. Reference paragraph 3 of EITF 02-5.
Mr. Qin Long
Rub A Dub Soap, Inc.
May 15, 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. Plea se 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