SEC Comment Letter for Cannabis Bioscience International Holdings, Inc. (CBIH) (CIK 0001411057) (CBIH) — Jan 13, 2010
Cannabis Bioscience International Holdings, Inc. (CBIH) (CIK 0001411057)
Date: Jan. 13, 2010 · CIK: 0001411057 · Accession: 0000000000-10-002275
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-146758
Referenced dates: October 1, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE VIA FACSIMILE AND U.S. MAIL January 13, 2010 Yiru Shi Chief Executive Officer and Chief Financial Officer China Infrastructure Co nstruction Corporation C915 Jia Hao Int’l Business Ctr., 116 Zizhuyuan Rd., Haidan District Beijing, China 100097 RE: China Infrastructure Construction Corporation Form 10-K for the Year Ended May 31, 2009 Form 10-Q for the Period Ended August 31, 2009 File No. 333-146758
Dear Ms. Shi: We have reviewed your response letter filed on December 28, 2009 and have the following comments. Where indicated, we think you should re vise your disclosures 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 necess ary in your explanation. Please understand that the purpose of our review process is to a ssist you in your compliance with the applicable disclosure requirements and to enhan ce 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 aspect of our review. Feel free to call us at the phone numbers listed below. FORM 10-K FOR THE YEAR ENDED MAY 31, 2009
General
1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like. These revisions should be included in your future filings. Financial Statements
3. Summary of Significant Acc ounting Policies, page F-6
General
2. We have read your response to comment six from our letter dated October 1, 2009. On page F-7, you indicate that all costs incurred for sh ipping and handling are included in cost of
Ms. Yiru Shi January 13, 2010 Page 2 sales. However, in your proposed disclosure , you indicate that out bound freight costs are included in selling, general and administrative expenses. Please clar ify whether all shipping and handling costs are included in cost of sales. If shipping and handling costs are significant and are not included in cost of sales, please disc lose both the amounts of such costs and the line item(s) on the income statement that include them. Refer to EITF 00-10.
3. We have read your response to comment seven from our letter dated October 1, 2009. Please revise your footnotes to disclose in a manner similar to your supplemental response that rewards or incentives given to your custom ers are treated as a reduction of revenue.
* * * * Please respond to these comments within 10 business days, or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our comments and provides any requested information. De tailed letters greatly f acilitate our review. Please file your response on EDGAR as a corresponde nce file. Please underst and that we may have additional comments after reviewin g your responses to our comments.
You may contact Ernest Greene, Staff Accountant, at (202) 5 51-3733, or in his absence, the undersigned at (202) 551-3769, if you have ques tions regarding comments on the financial statements and related matters. Sincerely, R u f u s D e c k e r Accounting Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
VIA FACSIMILE AND U.S. MAIL
January 13, 2010
Yiru Shi Chief Executive Officer and Chief Financial Officer China Infrastructure Co nstruction Corporation
C915 Jia Hao Int’l Business Ctr., 116 Zizhuyuan Rd., Haidan District
Beijing, China 100097
RE: China Infrastructure Construction Corporation
Form 10-K for the Year Ended May 31, 2009
Form 10-Q for the Period Ended August 31, 2009
File No. 333-146758
Dear Ms. Shi:
We have reviewed your response letter filed on December 28, 2009 and have the following comments. Where indicated, we think you should re vise your disclosures 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 necess ary in your explanation.
Please understand that the purpose of our review process is to a ssist you in your compliance with
the applicable disclosure requirements and to enhan ce 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 aspect of our review. Feel free to call us at the phone numbers listed
below.
FORM 10-K FOR THE YEAR ENDED MAY 31, 2009
General
1. Where a comment below requests additional disclosures or other revisions to be made,
please show us in your supplemental response what the revisions will look like. These
revisions should be included in your future filings.
Financial Statements
3. Summary of Significant Acc ounting Policies, page F-6
General
2. We have read your response to comment six from our letter dated October 1, 2009. On page
F-7, you indicate that all costs incurred for sh ipping and handling are included in cost of
Ms. Yiru Shi
January 13, 2010 Page 2
sales. However, in your proposed disclosure , you indicate that out bound freight costs are
included in selling, general and administrative expenses. Please clar ify whether all shipping
and handling costs are included in cost of sales. If shipping and handling costs are
significant and are not included in cost of sales, please disc lose both the amounts of such
costs and the line item(s) on the income statement that include them. Refer to EITF 00-10.
3. We have read your response to comment seven from our letter dated October 1, 2009.
Please revise your footnotes to disclose in a manner similar to your supplemental response
that rewards or incentives given to your custom ers are treated as a reduction of revenue.
* * * *
Please respond to these comments within 10 business days, or tell us when you will provide us with a response. Please provide us with a response letter that keys your responses to our
comments and provides any requested information. De tailed letters greatly f acilitate our review.
Please file your response on EDGAR as a corresponde nce file. Please underst and that we may have
additional comments after reviewin g your responses to our comments.
You may contact Ernest Greene, Staff Accountant, at (202) 5 51-3733, or in his absence, the
undersigned at (202) 551-3769, if you have ques tions regarding comments on the financial
statements and related matters.
Sincerely,
R u f u s D e c k e r
Accounting Branch Chief