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SEC Company Response from COMMERCE DEVELOPMENT CORP LTD (CIK 0001208790) — Dec 21, 2005

COMMERCE DEVELOPMENT CORP LTD (CIK 0001208790)
Date: Dec. 21, 2005 · CIK: 0001208790 · Accession: 0001056520-05-000227

AI Filing Summary & Sentiment

File numbers found in text: 333-104647

Referenced dates: November 30, 2005

Date
December 20, 2005
Author
Branch Chief
Form
CORRESP
Company
COMMERCE DEVELOPMENT CORP LTD (CIK 0001208790)

Letter

VIA EDGAR CORRESPONDENCE AND REGULAR MAIL Division of Corporate Finance United States Securities and Exchange Commission Form 10-KSB for the year ending December 31, 2004 Form 10-QSB for the quarters ending March 31, 2005, June 30, 2005 and September 30, 2005 File #333-104647

Dear Ms. Luckey and Ms. Crittendon:

We represent Commerce Development Corporation Limited (the "Company") regarding certain securities matters. The Company has received your letter dated November 30, 2005, with comments regarding certain periodic reports filed on behalf of the Company.

On behalf of the Company, we would like to request an extension to answer the comments set forth in the November 30, 2005 letter. We would request an extension to answer until December 28, 2005.

On behalf of the Company, we would appreciate your consideration in reviewing this request.

Very truly yours.
PARSONS LAW FIRM

Show Raw Text
CORRESP
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filename1.htm

PARSONS LAW FIRM

PARSONS LAW FIRM

ATTORNEYS AT LAW

SUITE 2070 SKYLINE
TOWER

10900 NE 4th
STREET

BELLEVUE, WASHINGTON
98004

(425) 451-8036 FAX
(425) 451-8568

www.parsonslaw.biz

James B. Parsons*
*Also admitted in Oregon and

jparsons@parsonslaw.biz
the Northern Mariana Islands

VIA EDGAR
CORRESPONDENCE AND REGULAR MAIL

December 20, 2005

Ms. Cicely Luckey,

Branch Chief

Ms. Yolanda
Crittendon,

Staff Accountant

Division of Corporate
Finance

United States
Securities and Exchange Commission

Washington, D.C.
20549

Mail Stop 4561

  Re: Commerce
  Development Corporation Ltd.

  Form 10-KSB for the
  year ending December 31, 2004

  Form 10-QSB for the
  quarters ending March 31, 2005, June 30, 2005 and

  September 30, 2005

  File #333-104647

Dear Ms. Luckey and Ms. Crittendon:

We represent Commerce Development Corporation Limited (the
"Company") regarding certain securities matters. The Company has received your
letter dated November 30, 2005, with comments regarding certain periodic reports
filed on behalf of the Company.

On behalf of the Company, we would like to request an
extension to answer the comments set forth in the November 30, 2005 letter. We
would request an extension to answer until December 28, 2005.

On behalf of the Company, we would appreciate your
consideration in reviewing this request.

Very truly yours.

PARSONS LAW FIRM

/s. James B. Parsons

JAMES PARSONS

JBP:kpc

cc: Andrew Mercer