Albert Lung
650.843.7263
alung@morganlewis.com
May 31, 2011
VIA EDGAR & EXPRESS MAIL
Kathleen Collins, Accounting Branch Chief
Division of Corporation Finance
United States Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street, N.W.
Washington, DC 20549-0306
| Re: | Pansoft Company Limited |
| | Form 20-F for the Fiscal Year Ended June 30, 2010 |
| | Filed on November 8, 2010 |
| | File Number: 001-34168 |
Dear Ms. Collins:
On behalf of Pansoft Company Limited (the “Company”), we submit this letter in response to the comments from the Staff of the Securities and Exchange Commission (the “Commission”) to the Company, dated May 16, 2011 (the “Comment Letter”), with respect to the Company’s filings referenced above. In the Comment Letter, the Staff requested the Company to respond within 10 business days, i.e., by May 31, 2011. Based on our prior conversation with the Staff, we hereby request an additional 10 business days to respond to the Comment Letter, i.e., by June 14, 2011. The extension is requested primarily because of the additional time required for the Company’s independent registered public accounting firm, Crowe Horwath (HK) CPA Limited, to complete its review of the response letter and the proposed amendments to the Form 20-F.
* * *
In connection with the Company’s response to the Comment Letter, the Company hereby acknowledges that:
| | · | the Company is responsible for the adequacy and accuracy of the disclosure in the filings; |
| | · | Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; 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 questions or comments as to the foregoing, please contact the undersigned.
| | Sincerely, |
| | |
| | /s/ Albert Lung |
| | |
| | Albert Lung |
| cc: | Megan Akst |
| | Staff Accountant |
| | Division of Corporation Finance |
| | Securities and Exchange Commission |
| | |
| | Guoqiang Lin |
| | Chief Executive Officer |
| | Pansoft Company Limited |
| | |
| | Allen Zhang |
| | Chief Financial Officer |
| | Pansoft Company Limited |
