SecProbe.io

September 16, 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 August 11, 2011 Form 10-Q/A for the Fiscal Quarter Ended March 31, 2011 Filed  August 11, 2011 File No. 001-34294

Dear Mr. Yuan:

We have reviewed your letter dated A ugust 11, 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 ten business days by amending your filing, 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 an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing 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 re fer to our letter dated August 2, 2011.
 Table of Contents, page 3

1. Notwithstanding your response to prior co mment 4, both your Forms 10-K/A and 10-Q/A
filed on August 11, 2011 continue to present an incorrect tabl e of contents and order of
disclosures.  Please ensure that all future fi lings include each of the required sections and
captions as set forth in the form requirements.  Refer to  http://www.sec.gov/about/forms/secforms.htm#1934forms
.

 Mr. Frank S. Yuan ASAP Expo, Inc. September 16, 2011 Page 2

Evaluation of Controls and Procedures, page 20

2. Your response notwithstanding, you continue to have two evaluations of disclosure
controls and procedures disclosed. The first,  in the last paragraph on page 20 and the
second, in the first paragraph on page 21.  In clusion of two disclo sure controls and
procedures reports may be confusing to readers.   Please confirm, if true, that in future
filings, please assess which of the paragraphs  best meets the requirements of Item 307
and exclude the other.
3. We note your continued belief that your di sclosure controls a nd procedures were
effective as December 31, 2010.  In your re sponse you refer to your belief that going
forward you will be “in position to perform and complete its report on internal controls
effectively due to the use of the correct Form as advised by the SEC Comment letters”.  It does not appear that you understood the nature of our prior comment which dealt with the
effectiveness of disclosure controls and procedures. Neither of these assessments is
related in any way to the Form on which you file your annual report.  Since you did not
include your assessment of internal controls over financial reporti ng, we do not believe
that your disclosure controls a nd procedures were effective.

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 G. Krikorian
Stephen G. Krikorian Accounting Branch Chief