Promotora Valle Hermoso, Inc.
301 East Pine Street, Suite 150
Orlando, FL 32801
July 31, 2009
Securities and Exchange Commission
Washington, D.C. 20549
| | RE: | Promotora Valle Hermoso, Inc. |
| | SEC Comment Letter dated July 8, 2009 |
| | Amendment No. 8 to Schedule 14C filed July 23, 2009 |
| | Form 10-K for fiscal year ended December 31, 2008 |
| | Form 10-Q for the Quarter Ended March 31, 2009 |
| | File No. 000-27199 |
Dear Sir/Madam:
We are submitting herein the responses of Promotora Valle Hermoso, Inc. (the “Company”) to the comments set forth in your comment letter dated July 27, 2009 on the captioned filing under the Securities Exchange Act of 1934, as amended.
Simultaneously with the filing of this correspondence, the Company has filed an Amendment to its 2008 Form 10-K (the “Amended 10-K”), and will shortly file an amendment to its quarterly report on Form 10-Q for the period ended March 31, 2009 (the “Amended 10-Q”).
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008 AND FORM 10-Q FOR THE PERIOD ENDED MARCH 31, 2009
General
1. Amended 10-K. The Amended 10-K contains the additional disclosures and updates requested by this comment.
1. Amended 10-Q. The Amended 10-Q contains the disclosures and updates requested by this comment.
2. Form 8-K. The Item 4.02 Form 8-K has been filed.
The Company is responsible for the adequacy and accuracy of the disclosure in the filing.
The Company acknowledges that 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 that the 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.
The Company is also aware that the Division of Enforcement has access to all information we provide to the staff of the Division of Corporation Finance in your review of our filing or in response to your comments on our filing.
Sincerely,
PROMOTORA VALLE HERMOSO, INC.
By: /s/ Alexey A. Kim
Alexey A. Kim
Chief Executive Officer
