| Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Room 4561 Washington, D.C. 20549-0303 | ||
| Attention: | Kathleen Collins Accounting Branch Chief Thomas Ferraro Senior Staff Accountant | |
Re: | CDC Corporation Form 20-F for the Fiscal Year Ended December 31, 2005 (filed June 21, 2006) Form 6-K Filed March 6, 2006 Form 6-K Filed April 13, 2006 Form 6-K Filed May 2, 2006 Form 6-K Filed May 26, 2006 File No. 000-30134 |
| 1. | We note from your response to comment number 1 that the Company filed a request for waiver with the Division’s Chief Accounting Office, relating to filing Item 3-09 financial statements for 17game Group and summarized financial information pursuant toItem 4-08(g) of Regulation S-X. We understand that you have received correspondence from the Division’s Chief Accountant denying your waiver request. Considering this, tell us the Company’s anticipated timing for amending filings to include Item 3-09 financial statements and Item 4-08 disclosures. | |
| Response:On November 29, 2006, the Company filed a request for waiver with the Division’s Chief Accounting Office relating to filing Item 3-09 financial statements of 17game Group. On December 7, 2006, the Company received correspondence from the Division’s Chief Accountant denying our waiver request. The Company is currently in the process of working with its independent auditing firm to complete the audit of the required financial information for 17game Group. Based upon the work completed to date, and after discussions with representatives at our independent auditing firm, the Company currently believes that it may be in a position to file an amended Form 20-F/A to include Item 3-09 financial statements of 17game Group and Item 4-08(g) disclosure by February 15, 2007. The Company undertakes to inform the Staff in the event the filing of its amended Form 20-F/A will be delayed beyond such date. |
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