Mail Stop 6010


      December 14, 2005



Suk Joo Ko
Director of Accounting Team
Mirae Corporation
#9-2, Cha Am-Dong
Chun An, Chung Chong Nam-Do 330-200
Republic of Korea



	Re:	Mirae Corporation
		Form 20-F/A 	Filed November 30, 2005
      File No. 000-30376


Dear Mr. Suk Joo Ko:

      We have reviewed your response letters dated November 18,
2005
and December 1, 2005 and subsequent filings and have the following
additional comments.  We have limited our review of your filing to
those issues we have addressed in our comments.  Where indicated,
we
think you should revise your document in response to these
comments.
If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In some of our
comments,
we may ask you to provide us with information so we may better
understand your disclosure.  After reviewing this information, we
may
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.




Form 20-F/A Filed November 30, 2005

Item 15. Controls and Procedures, page 33

1. We see that you have modified the language relating to the
effectiveness of your disclosure controls and procedures and it
does
not appear that your certifying officers have reached a conclusion
that your disclosure controls and procedures are effective. Please
revise the filing to definitively state your officers` conclusions
regarding the effectiveness of your disclosure controls and
procedures. If your certifying officers have concluded that they
are
not effective, you should clearly describe the basis for this
conclusion and the events that occurred which lead to this
assessment. Please revise to comply.

2. We see your disclosure that there have been "no significant
changes" in your internal controls and procedures. Please revise
your
disclosure to clearly indicate whether there was any change in
your
internal control over financial reporting that has materially
affected or is reasonably likely to materially affect your
internal
control over financial reporting, as required by Item 308(c) of
Regulation S-K.

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed decision.  Since the company and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.












      You may contact Kevin Kuhar, Staff Accountant, at (202) 551-
3662 or me at (202) 551-3603 if you have questions regarding these
comments on the financial statements and related matters.  In this
regard, do not hesitate to contact Angela Crane, Branch Chief, at
(202) 551-3554.



								Sincerely,



								Jay Webb
								Reviewing Accountant

Suk Joo Ko
Mirae Corporation
December 14, 2005
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