CUMBERLAND HILLS, LTD.
260 Newport Center Drive
Newport Beach, California 92660
Telephone: (949) 420-0504
August 29, 2012
Division of Corporation Finance
Securities and Exchange Commission
100 F Street NE
Washington D.C. 20549
Attn: | Pamela A. Long, Asst. Director | |
Edward M. Kelly, Senior Attorney | ||
Dale Welcome, Staff Accountant | ||
Anne M. McConnell, Staff Accountant |
Re: | Cumberland Hills Ltd. (“Registrant”) | |
Amendment No. 2 to Registration Statement on Form S-1 | ||
Filed on May 31, 2012 | ||
File No. 333-181784 |
Gentlepersons:
Please be advised that, on behalf of the Company, I hereby acknowledge the following:
● | Should the Securities and Exchange Commission (the “SEC”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the SEC from taking any action with respect to the filing; |
● | The action of the SEC or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
● | The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. |
Very truly yours,
By: | /s/ Joseph Isaacs | |
Joseph Isaacs, President |