SEC Comment Letter for Asia Electrical Power International Group, Inc. (CIK 0001306046) — Oct 3, 2005
Asia Electrical Power International Group, Inc. (CIK 0001306046)
Date: Oct. 3, 2005 · CIK: 0001306046 · Accession: 0000000000-05-050901
AI Filing Summary & Sentiment
File numbers found in text: 333-120114
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Mail Stop 3561
October 3, 2005
Yulong Guo
President
Asia Electrical Power International, Inc.
#703-1112 West Pender Street
Vancouver, BC V6E2S1 Canada
Re: Asia Electrical Power International Group, Inc.
Amendment No. 3 to Registration Statement on Form SB-2
Filed September 13, 2005
File No. 333-120114
Dear Mr. Guo:
We have reviewed your amendment and have the following
comments.
Where indicated, we think you should revise your document 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
information so we may better understand your disclosure. After
reviewing this information, we may 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 any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Management`s Discussion and Analysis or Plan of Operation, page 45
1. Please update your management`s discussion and analysis
comparing
fiscal years December 31, 2004 to December 31, 2003 to include a
discussion of the material changes in your financial condition and
results of operations for the interim period since your recent
fiscal
year end as compared with the similar interim period in the
preceding
fiscal year. See Item 303(b)(2) of Regulation S-B.
Liquidity and Capital Resources, page 52
2. We note that as of December 30, 2004 you had received $757,994
in
shareholder loans. Please update this disclosure to the most
recent
practicable date.
* * * *
As appropriate, please amend your registration statement in
response to these comments. You may wish to provide us with
marked
copies of the amendment to expedite our review. Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information. Detailed cover
letters greatly facilitate our review. Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.
You may contact Brian McAllister, Staff Accountant, at (202)
551-3341 or Michael Moran, Accounting Branch Chief, at (202) 551-
3841
if you have questions regarding comments on the financial
statements
and related matters. Please contact Matthew Benson, Staff
Attorney,
at (202) 551-3335 or David Mittelman, Legal Branch Chief, at (202)
551-3214 with any other questions you may have.
Sincerely,
H. Christopher Owings
Assistant Director
cc: Dena Khean
Asia Electrical Power International Group, Inc.
Via Fax - (604) 697-8898
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Yulong Guo
Asia Electrical Power International Group, Inc.
October 3, 2005
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