SecProbe.io

July 6, 2011
 Via E-mail

Mr. Frank S. Yuan Chief Executive Officer ASAP Expo, Inc. 345 S. Figueroa St., Suite M09 Los Angeles, CA  90071
Re: ASAP Expo, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed April 15, 2011 Form 10-Q for the Fiscal Quarter Ended March 31, 2011
Filed May 23, 2011 File No. 001-34294

Dear Mr. Yuan:
 We have reviewed your filings and have the following comments.  We have limited our
review of your filings to those is sues we have addressed in the comments below.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within te n business days by amending your filings, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe amendments are appropriate, pleas e tell us why in your response.
 After reviewing any amendments to your f ilings and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2010

 Facing Sheet

 Mr. Frank S. Yuan ASAP Expo, Inc. July 6, 2011 Page 2
 1. You appear to be using an outdated Facing Sh eet format. Please see Form 10-K and refer
to Release Nos. 33-8876 and 33-9002, eff ective February 4, 2008 and April 13, 2009,
respectively.  Please revise or advise.
2. The Commission file number presented on your Facing Sheet does not appear to be
correct.  Our records indicate that the Commission file num ber for ASAP Expo, Inc. is
001-34294.  Please revise or advise.

 Mr. Frank S. Yuan ASAP Expo, Inc. July 6, 2011 Page 3
 Table of Contents, page 3

3. Your table of contents appears to be that us ed in accordance with Regulation S-B.  Please
be advised that Regulation S-B has been in tegrated into Regulation S-K, as well as
Article 8 of Regulation S-X.  In future filings , please revise to present a table of contents
that complies with the re quirements of Form 10-K.

Evaluation of Controls and Procedures, page 20

4. Please clarify within this sect ion that your Chief Executive Officer also performs the role
of Chief Financial Officer.
5. You have referred to an outdated Evaluation Da te.  In this regard, you have defined such
date as “a date within 90 da ys prior to the filing of the Company’s December 31, 2010
Form 10-KSB.”  Item 307 of Regulation S-K re quires that the evalua tion take place as of
the end of the period co vered by the report.

6. We note your reference to the filing of a Fo rm 10-KSB for the year ended December 31,
2010.  Please remover references to this form as it is no longer used, nor was a Form 10-
KSB ever filed by the company.

7. Within the last sentence of this paragraph, you appear to confuse disc losure controls and
procedures with internal cont rols over financial reporting. These represent two separate
controls systems that must be  reported on separately.
 The definition of disclosure controls and pro cedures is set forth in Rule 13a-15(e).  You
must disclose management’s assessment of disclosure controls and procedures as
required by Item 307 of Regulation S-K.
 The definition of internal controls over financ ial reporting is set forth in Rule 13a-15(f).
We note your statements that “there are no significant deficienci es in the design or
operation of internal controls over financial re porting” and that “no material weaknesses
in [y]our internal controls over financial reporting” were not ed.  These statements do not
meet the criteria for management’s assessmen t of internal controls over financial
reporting.  Refer to Item 308 of Regulation S-K for the requirements of management’s
annual report.
8. In addition, please consider whether manageme nt’s failure to perform or complete its
report on internal control over financial repo rting impacts its conclusions regarding the
effectiveness of your disclosure controls and procedures as of December 31, 2010.

 Mr. Frank S. Yuan ASAP Expo, Inc. July 6, 2011 Page 4
 9. We note your statement that “there were no sign ificant changes in [y]our internal controls
over financial reporting...”  Please revise to indica te whether there was any
 change in
your internal control over financial reporti ng during your fourth fi scal quarter that
materially affected, or is reas onably likely to materially aff ect, your internal control over
financial reporting.

Certifications

10. Certifications must be in the exact form set forth in Item 601(b)(31) of Regulation S-K.
In this regard, we note that your certifi cation excludes the introductory language of
paragraph 4 and the language of paragraph 4( b) of Item 601(b)(31) of Regulation S-K.
Please file an amendment to your Form 10-K th at includes the entire  periodic report and a
new, corrected certification.

Form 10-Q for the Quarterly Period Ended March 31, 2011
 11. Where applicable, the above comments should be considered in revising your Form 10-Q
for the quarterly period ended March 31, 2011.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

 Mr. Frank S. Yuan ASAP Expo, Inc. July 6, 2011 Page 5
 You may contact Tamara Tangen, Staff A ccountant, at (202) 551-3443 if you have
questions regarding comments on the financial statem ents and related matters.   Please contact me
at (202) 551-3730 with any other questions.
Sincerely,
   /s/ Stephen Krikorian
Stephen G. Krikorian Accounting Branch Chief