Beijing Century Health Medical (SULU) Inactive
Filed: 14 Sep 06, 12:00am
Frascona Joiner Goodman and Greenstein, P.C.
4750 Table Mesa Drive
Boulder, Colorado 80305
ph: 303 494 3000
fx: 303 494 6309
September 14, 2006
Amanda McManus
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E. Mail Stop 4561
Washington, D.C. 20549
Re:
Super Luck, Inc.
Amendment No.3 to
Registration Statement on Form SB-2
Filed August 11, 2006
File No.: 333-134008
Dear Ms. McManus:
On behalf of Super Luck, Inc., a Delaware corporation (the “Company”), enclosed please find our responses to your comment letter dated August 31, 2006.
Use of Proceeds, page 3
1.
We have reviewed your new disclosure in response to our prior comment number 3; however, we are unable to locate new disclosure in the summary on page 3 indicating that if you raise 30% of the offering proceeds, all proceeds will be used to pay offering expenses. Please revise or advise.
This disclosure has been added to page 3.
Item 28. Undertakings, page 54
2.
Please include the undertakings required by Item 512(e) and (g) of Regulation S-B.
These undertakings have been added.
FRASCONA JOINER GOODMAN AND GREENSTEIN, P.C.
By: /s/ Gary S. Joiner, Esq.
- 1 -