HIGHWAY HOLDINGS LIMITED
Landmark North, Suite 1801, Level 18
39 Lung Sum Avenue
Sheung Shui
New Territories, Hong Kong
February 7, 2012
Via EDGAR
John Cash
Accounting Branch Chief
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | Highway Holdings Limited | |
Form 20-F for the Fiscal Year Ended March 31, 2011 | ||
Filed June 29, 2011 | ||
File No. 0-28990 | ||
Dear Mr. Cash:
By letter dated January 24, 2012, the staff of the Securities and Exchange Commission (the “Staff”) provided this company, Highway Holdings Limited, with comments to this company’s Annual Report on Form 20-F for the year ended March 31, 2011. This letter contains the responses of Highway Holdings Limited to the Staff’s comments.
Form 20-F for the fiscal year ended March 31, 2011
Item 5 – Operating and Financial Review and Prospects, page 32
Results of Operations, page 33
1. We agree that, in future annual filings, we will expand our results of operations to provide a more comprehensive and quantified discussion and analysis of the factors that impacted our results between comparative periods, including the items listed in the Staff’s comment letter.
* * * * *
As requested by the Staff, we hereby acknowledge that:
· | This Company is responsible for the adequacy and accuracy of the disclosure in its filings; |
· | 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 |
· | This Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Please direct questions regarding this letter or the Form 20-F to the undersigned at 011 86 755 2813 6056, or to Istvan Benko, the Company’s SEC counsel, at (310) 789-1226.
Very truly yours, | ||
/s/ ALAN CHAN | ||
Alan Chan
|
cc: Istvan Benko, Esq.