WILLIAMS LAW GROUP, P.A.
2503 W. Gardner Ct.
Tampa FL 33611
Phone: 813-831-9348
Fax: 813-832-5284
e-mail: wmslaw@tampabay.rr.com
April 15, 2011
Tonya Bryan
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. St., N.E.
Washington, D.C. 20549-7010
| Re: | Yaboo, Inc. |
| | Registration Statement on Form S-1 |
| | Amendment No. 5. |
| | File No. 333-164999 |
Dear Ms. Bryan:
We have filed on EDGAR the above Amendment No. 5 and the related response table which is attached to this letter.
Thank you for your consideration.
| | Sincerely, |
| | |
| | /s/ MICHAEL T. WILLIAMS, ESQ. |
| | |
| | Michael T. Williams, Esq. |
Comment Number | | Explanation |
| 1. | | We have revised our disclosure on this issue as follows: There are no “licensed” green foods restaurants in China. Instead, as what is known in China as a “green foods” restaurant, we focus on selling foods that meet “Green Food” standards set by the China Ministry of Agriculture. |
| 2. | | We have added the following disclosure to this paragraph: However, we have no written agreements with Mr. Jiang, Mr. Gao or Mr. Wang, our management, to loan these funds to us. |
| 3. | | The references to being in the development stage were deleted |
| 4. | | The financial statements have been updated |
| 5. | | We have filed both pages of the English Translation as Exhibit 3.3 |
