LAW OFFICES OF
DAVID J. LEVENSON
7947 Turncrest Drive
Potomac, Maryland 20854
| | (301) 299-8092 |
| | Fax: (301) 299-8093 |
| Admitted: MC, DC and VA | levensonfam@msn.com |
| (Not Admitted: MD) | |
April 27, 2009
H. Christopher Owings, Assistant Director
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| Re: | Dragon Jade International Ltd. |
| | Registration Statement on Form 20-F |
| | Filed March 9, 2009 |
| | File No. 0-53593 |
Dear Mr. Owings:
A review of the amendment filed yesterday indicates that certain revisions were not given effect. The purpose of this letter is to serve as an errata sheet. The revisions will be made in the next amendment.
(1) The table on page 3 omitted selected financial data for the period from inception to March 31, 2005,
| | From October 31, 2003 (Date of |
| | Inception) to March 31, 2005 |
| | |
| Net sales or operating revenues | $83,856 |
| Income (loss) from operations | (11,121) |
| Net income (loss) | (10,867) |
| Net income (loss) per share | (1.09) |
| Total assets | 114,011 |
| Net assets | (9,578) |
| Capital stock | 1,289 |
| Number of shares | 10,000 |
| Dividends per share | - |
(2) In the table on page F-3, for the eight months ended November 30, 2007, (a) the loss per share should have been (1.942) instead of (0.166), and (b) the weighted average common shares outstanding should have been10,000 instead of 117, 263.
(3) The following table should be substituted for the table on page F-18:
KASH STRATEGIC LIMITED
Statements of Changes in Stockholders' Deficit
For the Years Ended March 31, 2008, 2007 and 2006
| | | | | | | | | Retained | | | Other | | | Total | |
| | | Common | | | Earnings | | | Comprehensive | | | Stockholders' | |
| | | Shares | | | Stock | | | (Deficit) | | | Income | | | Deficit | |
| | | | | | | | | | | | | | | | |
| Balance, March 31, 2005 | | | 10,000 | | | | 1,289 | | | | (10,868 | ) | | | --- | | | | (9,579 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Net loss for the year | | | — | | | | — | | | | (3,530 | ) | | | — | | | | (3,530 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Cumulative translation adjustment | | | — | | | | — | | | | — | | | | (5,247 | ) | | | (5,247 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Balance, March 31, 2006 | | | 10,000 | | | | 1,289 | | | | (14,398 | ) | | | 5,247 | | | | (7,862 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Net loss for the year | | | — | | | | — | | | | (15,345 | ) | | | — | | | | (15,345 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Cumulative translation adjustment | | | — | | | | — | | | | — | | | | (2,447 | ) | | | (2,447 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Balance, March 31, 2007 | | | 10,000 | | | | 1,289 | | | | (29,743 | ) | | | 2,800 | | | | (25,654 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Net loss for the year | | | — | | | | — | | | | (22,910 | ) | | | — | | | | (22,910 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Cumulative translation adjustment | | | — | | | | — | | | | — | | | | (121 | ) | | | (121 | ) |
| | | | | | | | | | | | | | | | | | | | | |
| Balance, March 31, 2008 | | | 10,000 | | | $ | 1,289 | | | $ | (52,653 | ) | | $ | 2,679 | | | $ | (48,685 | ) |
Thank you for your attention. We regret any confusion these errata may cause in the review process. Please provide copies of this letter to your staff.
| | Sincerely, |
| | |
| | David J. Levenson |
