DAVIS & ASSOCIATES
(A PROFESSIONAL LAW CORPORATION)
-SECURITIES, BUSINESS & INTERNATIONAL LAWYERS-
LOS ANGELES NEWPORT BEACH
IRVINE SANTA MONICA
HONG KONG SWITZERLAND
Ritz Carlton Annex
(213) 400-200/ (310) 823-8300
fax (310) 301-3370
Respond To:
P.O. Box 12009
Marina Del Rey, CA
90295-3009
Don@securities-attys.com
November 23, 2012
Justin Dobbie
Legal Branch Chief
Tonya K Aldave
Staff Attorney
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, DC 20549
Re: JuQun, Inc.
Amendment No. 1 to Form 10-12G Registration Statement
Filed October 10, 2012
File No. 000-54823
Dear Mr. Dobble,
We have been employed by JuQun, Inc (the “Company”), to represent them in connection with this Amendment No. 1 to their Form 10-12G filing, which was filed on October 10, 2012.
I am responding to your letter of comments dated November 5, 2012. Amendment No 1 to the registration statement has just been filed. Attached is a copy of that document, marked to show changes.
The paragraph numbers set forth below match the numbered paragraphs in your letter with our response set out below each comment.
1. The Company acknowledges your comment.
2. Complied with.
3. Complied with.
4. Complied with.
5. Complied with.
6. Complied with.
7. Complied
8. We have added a column indicating the percentage of shares held after the offering.
9. Complied with.
-1-
10. Complied with.
11. Complied with
12. Complied with
13 Complied with. The Company’s revenues were zero for its fiscal year ended August 31, 2011 as well.
14. The Company expenses $1,000 per month for services provided without cost to the Company by its officers. Of the $1,000, $800 is valued for their services and $200 for office space. Since 2002, the expense of $12,000 per year has been offset to additional paid in capital. A majority of our operating expenses in the year ended August 31, 2012 have been for professional services for legal and accounting services. Such professional services totaled $149,980 for the year ended August 31, 2012.
15. Complied with. The officers of the Company have provided without cost to the Company office space which they privately own for the use of the Company which was valued at $200 per month.
16. Complied with.
17. Complied with.
18. Complied with.
19. Complied with.
Attached is a written statement from the Company as requested.
If you desire more information or have questions, please contact me direct on my cell phone at 213 400 2007.
We appreciate your assistance in this matter.
Very Truly Yours,
/s/
Donald G. Davis
-2-
JUQUN, INC.
JuQun, Inc., A Nevada Corporation (the “Company”), in responding to the Letter of Comments from the SEC dated November 5, 2012, directed to the Company’s filing of Form 10-12G with the SEC on October 10, 2012 (the “filing”), hereby acknowledges that:
1. The Company is responsible for the adequacy and accuracy of the Disclosure in the filing.
2. 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
3. The Company may not assert staff comments as a defense in any proceeding initiated the Commission or any person under the Federal Securities Laws of the United States.
JuQun, Inc.
By:_______________________
Tom Chia
Date: November , 2012