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SEC Company Response from Coda Octopus Group, Inc. (CODA) (CIK 0001334325) (CODA) — Sep 7, 2007

Coda Octopus Group, Inc. (CODA) (CIK 0001334325)
Date: Sept. 7, 2007 · CIK: 0001334325 · Accession: 0001144204-07-048420

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File numbers found in text: 333-143144

Date
Sept. 7, 2007
Author
Jason Reid
Form
CORRESP
Company
Coda Octopus Group, Inc. (CODA) (CIK 0001334325)

Letter

CODA OCTOPUS GROUP, INC.

West 25th Street

New York, New York 10001

September 7, 2007

VIA FACSIMILE (202-772-9202) AND EDGAR

United States Securities and Exchange Commission

F Street, N.E.

Washington, D.C. 20549

Attention: H. Yuna Peng, Esq.

Re:

Coda Octopus Group, Inc.

Registration Statement on Form SB-2

File No. 333-143144

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), Coda Octopus Group, Inc. (the “Company”) respectfully requests that the effective date of the registration statement referred to above be accelerated so that it will become effective at 4.00 p.m., Eastern Time, on Monday, September 10, 2007, or as soon thereafter as possible.

We hereby acknowledge the following:

·

that should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

CODA OCTOPUS GROUP, INC.

By: /s/ Jason Reid

Name: Jason Reid

Title: President and Chief Executive Officer

Show Raw Text
CORRESP
1
filename1.htm

    CODA
      OCTOPUS GROUP, INC.

    164
      West 25th
      Street

    New
      York, New York 10001

    September
      7, 2007

    VIA
      FACSIMILE (202-772-9202) AND EDGAR

    United
      States Securities and Exchange Commission

    100
      F
      Street, N.E.

    Washington,
      D.C. 20549

    Attention:
      H. Yuna Peng, Esq.

            Re:

              Coda
                Octopus Group, Inc.

    Registration
      Statement on Form SB-2

    File
      No. 333-143144

    Ladies
      and Gentlemen:

    Pursuant
      to Rule 461 of the General Rules and Regulations under the Securities Act of
      1933, as amended (the “Act”), Coda Octopus Group, Inc. (the “Company”)
      respectfully requests that the effective date of the registration statement
      referred to above be accelerated so that it will become effective at 4.00 p.m.,
      Eastern Time, on Monday, September 10, 2007, or as soon thereafter as
      possible.

    We
      hereby
      acknowledge the following:

          ·

            that
              should the Commission or the staff, acting pursuant to delegated
              authority, declare the filing effective, it does not foreclose the
              Commission from taking any action with respect to the
              filing;

          ·

            the
              action of the Commission or the staff, acting pursuant to delegated
              authority, in declaring the filing effective, does not relieve the
              Company
              from its full responsibility for the adequacy and accuracy of the
              disclosure in the filing; and

          ·

            the
              Company may not assert staff comments and the declaration of effectiveness
              as a defense in any proceeding initiated by the Commission or any person
              under the federal securities laws of the United States.

              CODA
                OCTOPUS GROUP, INC.

              By:
                /s/
                Jason
                Reid

              Name:
                Jason Reid

              Title:
                President and Chief Executive
                Officer