December 5, 2007
Via EDGAR and Facsimile
Division of Corporation Finance Securities and Exchange Commission 100 F St., N.E. Washington D.C. 20549 Attn: Anthony Watson Staff Accountant |
Re: | Asia Time Corporation |
| Item 4.02 of Form 8-K |
| Filed November 26, 2007 |
| File No. 0-51981 |
Dear Mr. Watson:
Based upon the Securities and Exchange Commission’s (the “Commission”) review of the above-referenced filing, the Commission issued a comment letter, dated November 27, 2007. As requested in the comment letter and in conjunction with the response to the comment letter, Asia Time Corporation (the “Company”) hereby acknowledges that:
| · | the Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
· | 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 |
· | 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. |
If you have any other questions concerning this letter, please do not hesitate to contact Anh Q. Tran, Esq. at (310) 552-5083.
Very truly yours,
| Asia Time Corporation | |||
| /s/ Kwong Kai Shun | |||
Kwong Kai Shun | |||
Chief Executive Officer, Chief Financial Officer and Chairman of the Board |
Asia Time Corporation
Room 1601-04, 16/F CRE Centre, 889 Cheung Sha Wan Road, Kowloon , HK
Tel: (852) 2310 0101 Fax: (852) 2310 0032