SecProbe.io

August 2, 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/A for the Fiscal Year Ended December 31, 2010
Filed July 19, 2011 Form 10-Q/A for the Fiscal Quarter Ended March 31, 2011 Filed  July 19, 2011 File No. 001-34294
Dear Mr. Yuan:
 We have reviewed your letter dated Ju ly 20, 2011 in connection with the above-
referenced filings and have the following commen ts.  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 that amendments are appropriate, please 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 may have addi tional comments.  Unless otherwise noted, where
prior comments are referred to they refer to our letter dated July 6, 2011.
 Form 10-K/A for the Fiscal Year Ended December 31, 2010, filed on July 19, 2011

 Facing Sheet

1. In future filings, do not include an “N/A” checkbox following the paragraph which refers
to Interactive Data. If the company is not yet subject to the Interactive Data requirements, leave both the Yes and the No boxes unchecked.
2. At the bottom of the Facing Sheet you are to state the aggregate market value of the
voting and non-voting common equity held by no n-affiliates computed using the price at
the last business day of your second fiscal quarter
.  In this regard, for this Form 10-K/A
for the year ended December 31, 2010 should refl ect the non-affiliate market value as of
June 30, 2010.

 Mr. Frank S. Yuan ASAP Expo, Inc. August 2, 2011 Page 2
 3. Remove the qualifications that you have in cluded after the mark et value amount.

Table of Contents, page 3

4. Notwithstanding your response, the table of contents is not compliant with that set forth
in the Form 10-K Official Text.  The It em numbers throughout your filing are also
incorrectly numbered.  We have the same observation regarding your Item numbers and
disclosures in the Form 10-Q/A filed on July  19, 2011. Revise the Item numbers and add
disclosures as necessary to comply with such Items.
Explanatory Note, page 3

5. Please revise to exclude any reference to Re gulation S-B as this regulation has been
superseded.  In this regard, the changes you have been asked to make are to bring your
disclosures into complian ce with Item 10, paragraph f of Regulation S-K and not Article
8 of Regulation S-X, which relates to  the audited financial statements.
6. Your reference to an evaluation date of Ju ly 14, 2011 should be corrected to reflect the
fact that the evaluation of the effectiveness of disclosure controls and procedures is made
as of the last day of the period, December 31, 2010. Revise accordingly.
7. When revising your Explanatory Note, please include a discussion of  the changes that
were made to the Forward-Looking Statements  section on page 4 and please consider
whether any other changes need to be made in response to other comments contained in
this letter.
Evaluation of Controls and Procedures, page 20

8. We note that you have provided revised di sclosure related to your evaluation of
disclosure controls and pro cedures on page 21.  These revi sions were meant to replace,
not to supplement, the last paragraph on page 20.  Revise accordingly.
9. We note your belief that “management’s fail ure to perform or complete its report on
internal controls over financ ial reporting did not significan tly impact its conclusions
regarding the effectiveness of [y]our disclo sure controls and procedures at December 31,
2010.”  Disclosure controls and procedures incl ude, “controls and procedures of an issuer
that are designed to ensure that in formation required to be disclosed  by the issuer in the
reports that it files or submits under the Act is recorded, processed, summarized and
reported , within the time periods specified in  the Commission’s rules and forms.”
Considering management's failure to provide its report on internal control over financial
reporting, along with the fact that the compa ny essentially filed its annual report on a
Form not in use for three years, it is uncl ear to us how you are able to continue to
conclude that your disclosure controls and procedures are effective.  Amend the Form 10-
K/A to disclose management's revised conclu sion on the effectiveness of your disclosure

 Mr. Frank S. Yuan ASAP Expo, Inc. August 2, 2011 Page 3
 controls and procedures as of the end of the fi scal year.  If you continue to believe that
your disclosure controls and procedures were  effective, please te ll us the factors you
considered and highlight for us those factors that supporte d your conclusion.

Form 10-Q/A for the Fiscal Quarter Ended March 31, 2011, filed on July 19, 2011

10. Ensure that revisions in response to the comm ents below are also applied to the Form 10-
Q for the quarterly period ended March 31, 2011, as applicable.
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/ Craig D. Wilson
Craig D. Wilson Senior Assistant Chief Accountant