China Finance Online Co. Limited
November 13, 2006
CONFIDENTIAL
TO: | Ms. Kristi Beshears Staff Accountant Division of Corporate Finance Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549 |
CC: | Mr. Daniel L. Gordan Branch Chief Division of Corporate Finance Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549 |
Re: | China Finance Online Co. Limited Form 20-F for the year ended December 31, 2005 (File No. 000-50975) |
Dear Ms. Beshears,
I refer to your fax of November 3, 2006 to China Finance Online Co., Limited (the “Company”) regarding SEC comments on the Company’s Form 20-F filed on May 23, 2006. Attached to this cover letter please find our responses to the SEC comments, which we are filing via EDGAR.
Please direct any future correspondence with respect to this matter to the Company as set forth below:
China Finance Online Co. Limited | ||
9th Floor of Tower C, Corporate Square | ||
No. 35 Financial Street | ||
Xicheng District, Beijing 100032 | ||
People’s Republic of China | ||
Tel: +86 (10) 5832 5288 | ||
Fax: +86 (10) 5832 5200 | ||
Attention: Jun Wang | ||
With a copy to: |
Ms. Kristi Beshears and Mr. Daniel L. Gordan, November 13, 2006 — Page 2
O’Melveny & Myers LLP | ||
Plaza 66, 37th Floor | ||
1266 Nanjing Road West | ||
Shanghai 200040 | ||
People’s Republic of China | ||
Tel: +86 (21) 2307-7068 | ||
Fax: +86 (21) 2307-7300 | ||
Attention: Todd Bissett, Esq. |
I would appreciate your acknowledging receipt of this letter and our responses to the SEC comments by emailing me at jwang@jrj.com.
Thank you for your assistance in this matter.
Very truly yours, | ||||
/s/ Jun Wang | ||||
Jun Wang | ||||
Chief Financial Officer China Finance Online Co. Limited | ||||
cc: | Howard Zhang, Esq. David Lin, Esq. Todd Bissett, Esq. |
Ms. Kristi Beshears and Mr. Daniel L. Gordan, November 13, 2006 — Page 3
Consolidated Statements of Cash Flows, page F-6
1. | We note from your response to comment 1 that you will properly attribute the effect of exchange rate changes to different activities of cash flows in future filings. Paragraph 101 of SFAS 95 states that exchange rate changes themselves do not give rise to cash flows, and their effects on items other than cash have no place in a statement of cash flows. Please confirm that you will present the effect of exchange rate changes on cash as a separate item in the reconciliation of beginning and ending balances of cash. |
Responses:
We confirm that in future filings we will present the effect of exchange rate changes on cash as a separate item in the reconciliation of beginning and ending balances of cash. |