TransAKT Ltd.
Unit 8, 3/F., Wah Yiu Industrial Centre
30-32 Au Pui Wan Street, Fo Tan, N.T. Hong Kong
December 21, 2015
VIA EDGAR
Securities and Exchange Commission
100 F. Street, NE
Washington, D.C. 20549-7410
| Attention: | Larry Spirgel, |
| Assistant Director |
Dear Sirs, Mesdames:
| Re: | TransAKT Ltd. | |
| Preliminary Information Statement on Schedule 14C | ||
| Filed December 1, 2015 | ||
| File No. 000-50392 |
We write in response to your letter of December 8, 2015 regarding the above referenced preliminary information statement on Schedule 14C. Concurrently with this response we have filed an amendment to the information statement to update certain information regarding the security ownership of management, and to amend disclosure regarding the procedure for completion of the reverse stock split approved by our shareholders. For your ease of reference, our responses to your comments are numbered below in a corresponding manner:
General
| 1. | We note your disclosure that the holder of the majority of outstanding shares provided approval by written consent for the reverse stock split. However, according to your beneficial ownership table no party owns a majority of the shares. Please specify who provided written consent for this action and additionally revise the beneficial ownership table accordingly. |
Response: The written consent for the reverse stock split was obtained from the following shareholders:
| ShareholderName | Security | TotalShares | Percentage |
| LiuJu–Wen | Common | 39,119,400.0 | 6.38% |
| ChangMing–Shao | Common | 28,016,666.0 | 4.57% |
| Yuk–ChingTam | Common | 28,000,000.0 | 4.56% |
| JingtianHe | Common | 28,000,000.0 | 4.56% |
| AuYeungKamHung | Common | 26,700,000.0 | 4.35% |
| Kang–WingHo | Common | 25,000,000.0 | 4.08% |
| Ming–HueiHung | Common | 22,500,010.0 | 3.67% |
| Chi–Ming(James)Wu | Common | 17,485,862.0 | 2.85% |
| JiaxianHe | Common | 15,000,000.0 | 2.45% |
| HungChiaChing | Common | 22,000,000.0 | 3.59% |
| HuangChiang–Shui | Common | 11,000,000.0 | 1.79% |
| LinHsieh–Tung | Common | 10,000,000.0 | 1.63% |
| HsiehChi–Hsien | Common | 7,650,000.0 | 1.25% |
| JunboWang | Common | 5,000,000.0 | 0.82% |
| JianfengLiang | Common | 5,000,000.0 | 0.82% |
| Ming–ShengSu | Common | 4,200,000.0 | 0.68% |
| TsaoChih–Ming | Common | 4,146,264.0 | 0.68% |
| TsengMing–Chih | Common | 4,035,000.0 | 0.66% |
| Chi–WahYam | Common | 2,500,000.0 | 0.41% |
| Wei–ChungLiu | Common | 5,000,000.0 | 0.82% |
| Rung–HuaChen | Common | 2,000,000.0 | 0.33% |
| 312,353,202.0 | 50.95% |
Please note that, other than Liu Ju-Wen, who was included in the beneficial ownership table, none of the shareholders in question hold in excess of five percent outstanding common shares. We have not therefore included any additional shareholders in our beneficial ownership table.
We trust the foregoing is in order, however please contact the undersigned should you required additional information. The Company acknowledges that:
| • | the Company is responsible for the adequacy and accuracy of the disclosure in thefiling; | |
| • | staff comments or changes to disclosure in response to staff comments do not foreclosethe 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 bythe Commission or any person under the federal securities laws of the United States. |
| Yours truly, | ||
| TRANSAKT LTD. | ||
| Per: | /s/Yam Chi-Wah | |
| Mr. Yam Chi-Wah | ||
| Chief Financial Officer | ||
