Frascona, Joiner, Goodman and Greenstein, P.C.
4750 Table Mesa Drive
Boulder, CO 80305
Ph: (303) 494-3000
Fax: (303) 494-6309
August 18, 2016
Christian Windsor
Special Counsel
Office of Financial Services
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, N.E., Stop 4720
Washington, D.C. 20549
Re:
First Asia Holdings Limited
Preliminary Information Statement on Schedule 14C
Amendment No. 1
Filed August 18, 2016
File No. 000-30801
Dear Mr. Windsor:
Please be advised that First Asia Holdings Limited., a Canadian corporation (the “Company”), has filed Amendment No. 1 to its Preliminary Information Statement on Schedule 14C today. This Amendment No. 1 was filed in response a verbal comment received by telephone on August 16, 2016.
Verbal Comment - In order to clarify why proxies are not being solicited for the Meeting, include disclosure in the 14C indicating what percentage of the shareholders have provided assurances to the Company that they expect to attend the Meeting in person and vote their shares in favor of the proposed action.
Response:
The following disclosure has been added to Amendment No. 1 of the Preliminary 14C Information Statement in the section titled VOTING:
The Company is not soliciting proxies for the Meeting because it has determined that it is not necessary to do so in order to establish a quorum or to have sufficient votes to approve the proposed reverse stock split. Company management has received assurances from shareholders holding approximately 58.5% of the Company’s issued and outstanding common stock indicating that they expect to attend the shareholder meeting in person and to vote their shares in favor of the proposed action.
Please feel free to contact me with any questions relating to the foregoing information. Thank you for your time and assistance with this matter.
FRASCONA JOINER GOODMAN AND GREENSTEIN, P.C.
By: /s/ Gary S. Joiner, Esq.
