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SEC Comment Letter for Ilustrato Pictures International Inc. (ILUS) (CIK 0001496383) (ILUS) — Nov 20, 2012

Ilustrato Pictures International Inc. (ILUS) (CIK 0001496383)
Date: Nov. 20, 2012 · CIK: 0001496383 · Accession: 0000000000-12-063170

Regulatory Compliance Financial Reporting Internal Controls

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File numbers found in text: 001-35316

Date
November 20, 2012
Author
/s/Craig H. Arakawa
Form
UPLOAD
Company
Ilustrato Pictures International Inc. (ILUS) (CIK 0001496383)

Letter

November 20, 2012 Via Email Mr. Brian Hammond Chief Executive Officer Superior Venture Corp . Suite 220 -2 Old Brompton Road South Kensingt on, London SW7 3DQ

Re: Superior V enture Corp . Form 8 -K Filed November 9 , 2012 File No. 001-35316

Dear Mr. Hammond :

We have reviewed your filing and have the following comments. Where indicated, we think you should revise your document 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 necessary in your explanation. In so me of our comments, we may ask you to provide us with more information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.

Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance 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 any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter.

Form 8 -K filed November 9, 2012

1. Your Form 8 -K announcing your share exchange agreement with Ilustrato Pictures Ltd does not include information on a change in accountants. Please revise to provide the disclosures under Item 4.01 related to your change in certifying accountant to comply with Item 304 of Regulation S -K.

As appropriate , please amend you r filing and respond to these comments within five business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendment to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information. Detailed cover letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

Brian Hammond Superior Venture Corp . November 20 , 2012 Page 2

We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information in vestors require for an informed investment decision. 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 conne ction with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securiti es laws of the United States.

In addition, please be advised that the Division of Enforcement has access to all information you provide to the staff of the Division of Corporation Finance in our review of your filing or in response to our comments on your filing.

You may contact me at (202) 551-3650 if you have questions regarding our comments.

Sincerely,
/s/Craig H. Arakawa

Show Raw Text
November 20, 2012

Via Email
Mr. Brian Hammond
Chief Executive  Officer
Superior Venture Corp .
Suite 220 -2 Old Brompton Road
South Kensingt on, London SW7 3DQ

Re: Superior V enture Corp .
 Form 8 -K
Filed November 9 , 2012
File No. 001-35316

Dear Mr. Hammond :

We have reviewed your filing and have the following comments.  Where indicated,  we
think you should revise your document 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 necessary in your explanation.  In so me of our comments, we may ask
you to provide us with more information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

 Please understand that the purpose of our review process is to assist  you in your
compliance with the applicable disclosure requirements and to enhance 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 any other aspect of our review.  Feel free to call us at the
telephone number  listed at the end of this letter.

Form 8 -K filed November 9, 2012

1.  Your Form 8 -K announcing your share exchange agreement with Ilustrato  Pictures Ltd
does not include information on a change in accountants.  Please revise to provide the
disclosures under Item 4.01 related to your change in certifying accountant to comply
with Item 304 of Regulation S -K.

 As appropriate , please amend you r filing and respond to these comments within five
business days or tell us when you will provide us with a response.  You may wish to provide us
with marked copies of the amendment to expedite our review.  Please furnish a cover letter with
your amendment  that keys your responses to our comments and provides any requested
information.  Detailed cover letters greatly facilitate our review.  Please understand that we may
have additional comments after reviewing your amendment and responses to our comments.

Brian Hammond
Superior Venture Corp .
November 20 , 2012
Page 2

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information in vestors require for an
informed investment decision.  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 conne ction with responding to our comments, please provide, in writing, a statement
from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securiti es laws of the United States.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Division of Corporation Finance in our review of your
filing or in response to our comments on your  filing.

You may contact me at (202)  551-3650 if you have questions regarding our comments.

       Sincerely,

       /s/Craig H. Arakawa

       Craig H. Arakawa
       Staff Accountant