(212) 701-3139

September 1, 2005

Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-0405

Re: Global Sources Ltd.
Form 20-F for the year ended December 31, 2004
Filed May 13, 2005
File No. 333-0-30678

Dear Mr. Spirgel:

On behalf of Global Sources Ltd. (the "Company"), set forth below are the
Company's responses to the Comment Letter of the Staff dated August 10, 2005.
For the convenience of the Staff, the Staff's comments are repeated below and
the responses of the Company immediately follow each comment. Each of the
responses set forth below are based upon the information and representations of
the Company provided to us.

Item 5. Operating and Financial Review and Prospects

Results of Operations- Fiscal 2004 and 2003, page 28

1. Your current disclosures mostly indicate areas of change, but they do
not provide the reader with an understanding of the underlying
business and other drivers affecting your results of operations and
financial position, they do not quantify or indicate the relevant
weight of revenue categories, and the disclosures do not provide an
indication that past results are indicative of future performance. In
this respect, your disclosures do not comply fully with the
requirements or intent of Item 303 of Regulation S-K.

-2-

For example, you indicate in your discussion of revenue, that revenue derived
from your online and other media services segment increased 5% from 2003. It is
not clear from your disclosures what specific segment revenue categories
contributed to the increase and why. It is not clear whether the revenue surge
was due to creating and hosting websites, banner advertising, trade magazine
subscriptions or magazine advertising, etc. It is not clear what the underlying
business drivers were that contributed to the year-over-year revenue category
increase or if you expect this trend to continue.

Please revise to provide a comprehensive discussion of your results of
operations in accordance with Item 303 of Regulation S-K.

Response: The Company will respond to the Staff's comment by revising its
disclosure to make changes such as those shown in the following version of the
applicable section (bold underlined sections identify additions):

Fiscal Year 2004 Compared to Fiscal Year 2003

Revenue

Our total revenue grew to $105.8 million during the year ended
December 31, 2004 from $91.7 million during the year ended December 31,
2003, a growth of 15%. Our online and other media services revenue grew by
$4.6 million or 5% to $92.3 million during the year ended December 31,
2004, as compared with $87.7 million during the year ended December 31,
2003 due primarily to a 9% growth in our China market and the growth in our
Hong Kong, Japan and USA markets offset by drop in some of our other
markets during the year. "Online and other media services" revenue from
China grew by 9% in 2004 compared to 2003. China represented 45% of "Online
and other media services" revenue in 2004 compared to 43% in 2003. Our
exhibitions revenue grew from $3.3 million during the year ended December
31, 2003 to $13.0 million during the year ended December 31, 2004, a growth
of 294%, due mainly to an increase in the number of our China Sourcing
Fairs events held in year 2004. In 2004 we held six China Sourcing F airs
versus only one in 2003.

We have made substantial progress in developing our customer base in
China, our largest market. Total revenue from China grew by 26% during the
year ended December 31, 2004 compared to the year ended December 31, 2003
partially mainly as a result of an increase in China Sourcing Fairs
revenue. China accounted for 47% of total revenue during the year ended
December 31, 2004 compared to 43% of total revenue during the year ended
December 31, 2003. We expect China's percent of the total to continue to
grow and China's revenue overall to continue to grow.

-3-

Liquidity and Capital Resources, page 34

2. Your discussions of cash flows from operating, investing and financing
activities appear to be a mechanical recitation of your cash flow
statement. Please revise to provide not only a "discussion" but also an
"analysis" of historical information as well as known trends, demands,
commitments, events or uncertainties that will result in your liquidity
increasing or decreasing in any material way. In addition, revise your
disclosures of capital resources in a similar fashion to provide the reader
with a clear, cohesive view of your liquidity and capital resource needs as
seen through the eyes of management. For example, you should have discussed
and analyzed the business demands, events and needs that led management to
purchase $131.4 million and sell $157.3 million worth of securities.

Response: The Company will respond to the Staff's comment by adding
disclosure such as the following disclosure in the applicable section:

Operating Cashflows

Advance payments received from customers were $30,195 as of
December 31, 2004, compared to $27,454 as at December 31, 2003,
improving the Company's liquidity. A majority of its customers in
China pay the Company in advance for its Online and other media
services business. The Company Exhibitions business collections
are all advance payments. The Company expects the growth in its
revenues from China to continue and the Company plans to launch
more Exhibition events in the future. As a result, the Company
expects that the advance payments received from customers to
continue to increase in the future as its revenue increases.

Receivable from sales representatives was reduced from
$3,883 as at December 31, 2003 to $3,407 as at December 31, 2004.
However, the Company expects the receivable from sales
representatives to slightly increase due to expected growth in
its China business and its Exhibitions business.

Investing and Financing Cashflows

As and when the Company needs additional funds for capital
acquisitions the Company can raise additional capital for the
remainder of $259,500 under its Form F-3 shelf filing dated May
21, 2004.

The Company invests its excess cash in available-for-sale
securities to generate income from interest received as well as
capital gains, while the funds are held to support the Company's
business. The majority of the available-for-sale securities have
maturities of less than 3 months.

-4-

Generally the Company holds the securities with specified
maturity dates such as Treasury Bills until their maturity but
the securities managed by high quality institutions that do not
have fixed maturity dates are generally sold on a quarterly basis
and proceeds reinvested in similar securities. The $157,253 of
sales of available-for-sale securities during the year 2004,
consists of $128,453 securities sold or matured and reinvested
and $28,800 withdrawn from available-for-sale securities during
the year to pay for a major one-time capital expenditure of
$19,400 and $9,400 in repayment of the loan owed to a
shareholder.

The Company does not engage in buying and selling of
securities with the objective of generating profits on short-term
differences in price.

Capital Resources

The Company anticipates that its cash and securities on hand
and expected positive cash-flows from its operations will be
adequate to satisfy the Company's working capital, capital
expenditure requirements and cash commitments based on the
current levels of the Company's operations.

Item 8. Financial Information

Note 2 Summary of Significant Accounting Policies

(d) Available-for-sale Securities, page 54

3. Please tell us how you determined, in accordance with paragraph 12 of SFAS
115, the classification of securities bought and sold in 2004 as available
for sale and not trading.

Response: The Company invests its excess cash in readily marketable
securities managed by high quality institutions and in government-backed
securities such as US Treasury bills.

The Company's intention in keeping its excess cash in these securities is
to generate income from interest received as well as capital gains, while
the funds are held to support the Company's business. The majority of the
available-for-sale securities are short-term with a maturity of less than 3
months.

The Company records sales of securities upon their maturity or sale.

-5-

As per paragraph 12 of SFAS 115 "Accounting for Certain Investments in Debt and
Equity Securities", securities that are bought and held principally for the
purpose of selling them in the near term (thus held only for a short period of
time of generally hours or days) are to be classified as trading securities.
Trading generally reflects frequent buying and selling, and trading securities
are generally used with the objective of generating profits on short-term
differences in price.

Investments not classified as trading securities (nor as held-to-maturity
securities) shall be classified as available-for-sale securities.

As the Company's objective and intent is not to generate profit on short-term
differences in price and since the Company does not frequently buy or sell the
securities in order to profit from short-term price fluctuations, the Company
classifies its investments as available-for- sale securities, in accordance with
US GAAP.

(q) Minority Interest, page 57

4. Quantify in this footnote the amount of dividends that must be paid by
eMedia Asia Ltd. in order to trigger CMP's obligation to pay $6,000 to the
company. Discuss under Liquidity in MD&A the business purpose of this
arrangement and management's expectations of receiving this payment from
CMP, and advise us.

Response: As per the agreement with the Company's minority shareholder, UBM
Asia B.V. (CMP), $6,000 is payable by CMP only by applying any and all of
the dividends paid by the Company's subsidiary, eMedia Asia Ltd. (eMedia).
Such dividends are to be applied first against the interest due and
secondly, towards the principal sum.

As of December 31, 2004, the balance sheet of eMedia shows accumulated
losses of $4,094. Under the laws of the country of incorporation of eMedia,
a company cannot pay dividends unless it has positive retained earnings.

eMedia is currently profitable. However based on the current level of
profitability, the Company does not expect eMedia to pay any dividends in
next five years. Due to the contingent nature of the re-payment, the
Company did not record in its balance sheet the promissory note receivable
of $6,000 and no interest income was accrued.

As the Company does not expect eMedia to pay dividends in the near term,
the Company did not discuss the above arrangement under the liquidity
section in its MD&A. The Company will start to discuss the recoverability
in the Company's MD&A once eMedia starts to pay dividends.

Note 14 Income Taxes, page 66

-6-

5. We note, notwithstanding the fact that the company's subsidiaries subject
to income tax have apparently generated taxable income in each of the last
three fiscal years; the company continues to fully reserve its deferred tax
assets. This policy suggests it is management's belief that it is more
likely than not that the company will not realize any of the net deferred
tax assets, which would mean management has concluded that there is a
greater than 50 percent likelihood that the company's subsidiaries subject
to tax will not generate any future taxable income through the date the
company's net operating loss carryforwards expire. If this is so, we
believe comprehensive disclosure should be provided to alert investors of
this negative view held by management. In this disclosure you should
explain to investors, in detail, your consideration of all available
negative and positive evidence that formed the basis for your conclusion
and why this conclusion is reasonable given that deferred tax assets were
re alized by the company in past fiscal years. Also, please advise us in
detail of your basis for the full valuation allowance. We refer you to
paragraphs 20-25 of SFAS No. 109.

Response: The break-down of the deferred tax assets of $7,410 as at
December 31, 2004 is as follows:

Deferred tax assets relating to tax losses
in two of the Company's Hong Kong subsidiaries
and a Cyprus subsidiary $ 19

Deferred tax assets relating to tax losses in the
Company's US subsidiary $ 7,391

Total deferred tax assets as at December 31, 2004 $7,410

The Company's deferred tax assets arose primarily from the past tax losses of
$17,188 in its US subsidiary.

These losses resulted primarily from non-cash compensation expenses relating to
a share award to the Company's chairman and chief executive officer by the US
subsidiary as discussed in Note 22 to the Company's financial statements.

The taxable profits/ (losses) of the Company's US subsidiary during the last
three years were as follows:

B/f loss at beginning of 2002: ($17,275)

Year-2002: ($45) loss
Year-2003: $70 profit
Year-2004: $62 profit
C/f loss at end of 2004: ($17,188)

-7-

Though the US subsidiary is currently profitable, its operations are very small
and the Company does not expect its operations to increase substantially in near
future to generate enough profits to realize any material amounts of the
deferred tax assets before the net operating losses carried forward expire.
Accordingly the Company provided for a full valuation allowance.

The Company's US subsidiary provides certain administrative services to its
related company and receives a fee from its related company for the services
rendered. It does not generate any revenue from third parties for the Company
and its inability to realize the deferred tax assets has no impact on the
Company's profitability or financial position.

Operations of the Company's two Hong Kong subsidiaries and Cyprus subsidiary
mentioned above are also very small. Following are the results of the Company's
Hong Kong and Cyprus subsidiaries:

Hong Kong Subsidiaries Cyprus Subsidiary
B/f loss at beginning of 2004 ($101) ($48)
Profit/ (loss) for the year 2004 $6 ($16)
C/f loss at the end of 2004 ($95) ($64)

Accordingly, the Company has provided for a full valuation allowance.

The Company will include a discussion such as the following with respect to the
Company's deferred tax assets in its MD&A:

The Company recorded a full valuation allowance for the deferred tax
assets of $7,410 as at December 31, 2004 as it was more likely than
not that they would not be realized. These deferred tax assets
resulted from the net operating losses in some of the Company's
subsidiaries.

Note 19 Segment and Geographic Information, page 69

6. Tell us in detail how you determined your operating segments under
paragraphs 10-16 of SFAS 131. Also if you have aggregated operating
segments into reportable segments, tell us how you determined that you met
the criteria for aggregation in paragraph 17 of SFAS 131, including the
requirement that the segments have similar economic characteristics. To
help us better understand your analysis and conclusion provide us with a
copy of the report(s) that the chief operating decision maker uses to
allocate resources and assess performance. We may have further comments
after the review of your response.

-8-

Response: The Company provides trade information in print, online, and in
face-to-face exhibitions for the marketing and sourcing needs to its supplier
and buyer community. The Company's solutions are based on 35 years as a trade
magazine publisher and 9 years as an online marketplace operator.

Prior to 2002, the Company offered separate Print and Online services to clients
based on its separate published price lists. In year 2002, the Company decided
to consolidate the price list into one "Total Solution" price list so as to
avoid clients picking only Online service or only Print service. The Company
changed its sales strategy such that clients must buy both services and hence
the Total Solution price list.

The Company launched its major new line of exhibitions known as China Sourcing
Fairs in year 2003.

Segment reporting

SFAS 131 requires that the Company report a segment profit or loss, segment
assets and related items. A segment is a component of an enterprise that engages
in business activity whose operating results are reviewed regularly by the
Company's chief operating decision maker to make decisions about resources to be
allocated to the segment and assess its performance, and for which discrete
financial information is available.

The Company's chief operating decision maker is its Board of Directors, to which
management reports and which makes the decisions about resources to be allocated
to each segment and to assess its performance.

SFAS 131 permits disclosure of the Company's segment reporting as long as it is
supported by the form and content of the Company's financial report to its Board
of Directors for which there should be a reasonable basis for the allocation
between the Company's reported segments.

For financial statement and segment reporting, the Company combines the Online
services and Print services because the pricing of Print services and Online
service is combined as part of the Company's "Total Solution Package" price
list.

As disclosed in the segment note to the Company's financial statements, revenues
for the Company's Print and Online services are reported separately to the
Company's Board of Directors, as the Company's chief operating decision maker.
For reporting to the Board of Directors, the Company estimates the allocation of
revenue between Print and Online services based on the Company's own
determination of relative fair value of each component.

Attached as Annex A is the financial report that management of the Company
furnished to the Board of Directors for its review of the Company's performance.
The Board of Directors also uses this information to allocate resources to the
different segments.

-9-

Note 24 Directors Purchase Plan, page 73

7. Please tell to us your accounting treatment of the options in your
directors purchase plan, including any other reference to authoritative
accounting literature.

Response: As per the Directors Purchase Plan each director could purchase
up to 20,000 common shares of the Company, under such terms and conditions
as defined by the Directors Purchase Plan ("the Plan").

Each year on January 1, each director fulfilling the eligibility criteria
of the Plan is entitled to an option which expires on February 28 of the
same year. The option is to purchase up to 20,000 shares.

As per the current terms and conditions, directors purchasing the shares
under the plan pay 10% of the purchase price on or before February 28th of
the current financial year. The purchase price is the average closing price
of the shares for the last five trading days of the immediately preceding
financial year.

Under the current terms of the Plan, the ownership of the shares will
transfer after four years and the directors have to pay the remaining 90%
balance on or before that final date. The shares will be issued to the
directors only upon expiry of the holding period for these shares. If a
director fails to pay the balance of 90% of the purchase price on or before
the end of the holding period, the 10% deposit paid by the director will be
forfeited. However, the directors do not need to render any additional
service to the Company and there is no forfeiture of the shares upon the
director leaving the Company. Therefore, these shares have been accounted
for on an advance share-subscription basis.

The Company's accounting treatment is as follows:

(i) When a director purchases the shares and pays 10% of the purchase
price:

Bank Account - Debit

Additional paid in capital - Credit

(ii) When balance of 90% is received from the director.

Bank Account - Debit

Additional paid in capital - Credit

(iii) When the shares are issued upon expiry of the holding period for
these shares: Par value of the issued shares is transferred from
additional paid in capital account to common share capital account.
The following is the accounting entry:

-10-

Additional paid in capital - Debit (with the par value of $0.01 for
each issued share)

Common Share Capital Account - Credit (with the par value of $0.01 for
each issued share)

(iv) The net effect is:

Bank Account - Debit (with the money received from the directors based
on prevailing market price)

Common share capital Account - Credit (with the par value of $0.01 for
each share issued)

Additional paid in capital - Credit (with the share premium amount on
the shares issued)

All directors meet the APB 25 criteria to allow the option grants to
be accounted for under APB 25.

Under APB Opinion 25, the compensation expense relating to the share
options granted is measured as the difference between the quoted market
price of the stock at the grant date and the price to be paid by the
directors (exercise price) on the measurement date. The exercise price and
number of shares are both established on January 1 of each year, hence,
fixed plan accounting is applied.

For 2002, 2003 and 2004, the option price for grants to directors was equal
to or higher than the fair market value at date of grant, therefore, there
was no stock compensation expenses associated with the Directors Purchase
Plans during these years. For the grants relating to the 2001 year, the
option price was established at 85% of fair market value at date of grant.
The stock compensation expense related to these grants of $11 was not
recorded because the effect was not material.

In its Annual Reports, the Company will make the revisions to its footnote
disclosure to the financial statements in order to make the foregoing
clearer to the reader. The footnote disclosure to the financial statements
will be such as the following:

Directors Purchase Plan

A 2000 Non-Employee Directors Share Option Plan was approved on
October 26, 2000 by the shareholders of the Company. Each eligible
Director was entitled to an option to purchase up to 20,000 common
shares at a price established at year end.

-11-

The option was exercisable before the end of each February following
the year end at which the option price was established. The
non-employee Directors have the right to decline all or part of the
award, which is non-transferable.

For grants attributable to the 2001 year, the option price was fifteen
percent less than the average closing price of the shares for the last
five trading days of the previous calendar year. The award vested over
four years with one quarter of the shares vesting each year. Full
payment was required upon exercising the option. Upon resignation of
an eligible Director, all unvested shares would be forfeited and the
option price received for the forfeited unvested shares would be
refunded. Only one Director accepted the offer on February 10, 2001
for the 24,200 shares granted under the option. The $164 received as
proceeds of this plan was included in additional paid-in capital. On
February 28, 2002, 2003 and 2004, the Company issued to the Director
the 6,050, 6,050 and 6,050 common shares, respectively, that vested on
those dates.

On November 1, 2001, the terms of the plan for prospective grants were
amended to require only 15% of the exercise price to be paid upon
exercise date and that the resignation of a director would no longer
result in a forfeiture of the subscribed shares. The plan entitles the
directors to a grant of options at a price established at the prior
yearend. The ownership of the awards will transfer after four years.
Optionees must pay 15% of the option price, which is the average
closing price of the shares for the last five trading days of year
2001, at the time of exercising the option. The balance of 85% must be
paid on or before the end of the holding period. The resignation of a
Director following his or her exercise of the Grant of Options and
payment of the Option Price shall not cause a forfeiture of the
subscribed shares. All the eligible non-employee Directors accepted
the offer before February 28, 2002. The $50 received towards the 15%
of the option price was included in additional paid in capita l.

On February 27, 2002, the terms of the plan for prospective grants
were amended to require only 10% of the exercise price to be paid upon
exercise date. The plan entitles the directors to a grant of options
at a price established at the prior yearend. The ownership of the
awards will transfer after four years. Optionees must pay 10% of the
option price, which is the average closing price of the shares for the
last five trading days of year 2002, at the time of exercising the
option. The balance of 90% must be paid on or before the end of the
holding period. The resignation of a Director following his or her
exercise of the grant of options and payment of the option price shall
not cause a forfeiture of the subscribed shares. Three eligible
directors accepted the offer before February 28, 2003. The $30
received towards the 10% of the option price was included in the
additional paid in capital.

-12-

On May 8, 2003, shareholders approved the amendments to the 2000
Non-Employee Directors Share Option Plan to allow both employee and
non-employee Directors to participate prospectively in the plan. The
plan was renamed as the Directors Purchase Plan by the Board of
Directors on August 14, 2003.

Directors purchasing the shares under the plan pay 10% of the purchase
price, which is the average closing price of the shares for the last
five trading days of the 2003 year, on or before February 28, 2004.
The balance of 90% is paid by February 28, 2008 and the shares will be
issued thereafter. The resignation of a Director following his or her
purchase of the shares and payment of the 10% initial installment
shall not cause a forfeiture of the purchased shares. Six directors
opted to purchase 24,200 shares each and one director opted to
purchase part of the 24,200 shares. The amount of $92 received towards
the 10% of the purchase price was included in additional paid in
capital.

As per the terms of the Directors Purchase Plan, Directors purchasing
the shares under the plan in year 2005 will pay 10% of the purchase
price which is the average closing price of the shares for the last
five trading days of the year 2004, on or before February 28, 2005.
The balance of 90% will be paid by February 28, 2009 and the shares
will be issued thereafter. The resignation of a Director following his
or her purchase of the shares and payment of the 10% initial
installment shall not cause a forfeiture of the subscribed shares.
Five directors opted to purchase 22,000 shares each. The amount of
$118 received towards the 10% of the purchase price will be included
in additional paid in capital.

Other

8. We note you have significant operations in China and Hong Kong SAR. In
light of the restriction on the payment of dividends and other restrictions
under PRC law, it appears it may be necessary for you to provide condensed
financial information of the registrant prepared in accordance with 12-04
of Regulation S-X and the disclosures required by 4-08(e) of Regulation
S-X, pursuant to Item 17(a) of Form 20-F. Please revise accordingly or
advise us in detail.

Response: The Company appoints independent sales representatives in China
and Hong Kong to sell its services in China and Hong Kong for which they
earned sales commissions from them. The Company has 2 subsidiaries in China
which have distributable dividends of about $90 as at December 31, 2004.
Chinese legal counsel has advised the Company that there is no legal
restriction in China for the Company's Chinese subsidiaries to pay
dividends out of China.

-13-

Hong Kong has its own independent corporate law and is not subject to the
PRC business law. Hong Kong legal counsel has advised that there is no
legal restriction in Hong Kong for payment of dividends out of Hong Kong.

The majority of profits and retained earnings of Global Sources Ltd. are
recorded in Cayman Islands subsidiaries. Also, there are no restricted net
assets from the consolidated subsidiaries that exceed 25% of the
consolidated net assets. Hence, no disclosure under Rule 12-04 and 4-08(e)
or Regulation S-X is required.

The Company is prepared to make the changes indicated in its responses to
the Staff's comments numbers 1, 2, 5 and 7 in an amendment to its 2004 Form
20-F, but, in light of the Company's responses to the Staff's comments, the
Company respectfully requests that the Company be permitted to add the
additional disclosures in response to comments number 1, 2, 5 and 7 in future
filings, without filing an amendment to its Form 20-F for the year ended
December 31, 2004.

The Company hereby acknowledges that (1) the Company is responsible for the
adequacy and accuracy of the disclosure in the filing to which this response
letter relates, (2) staff comments or changes in response to staff comments in
the disclosure in the filing to which this response relates do not foreclose the
Commission from taking any action with respect to such filing and (3) the
Company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

Comments or questions regarding any matters with respect to the foregoing
may be directed to the undersigned at (212) 701-3139.

Very truly yours,

/s/ Michael J. Ohler
------------------------
Michael J. Ohler

cc: Eddie Heng Teng Hua,
Chief Financial Officer
Global Sources Ltd.
James J. Clark, Esq.

Annex A

GSOL BOARD MEETING
FEBRUARY 28, 2005

STATEMENT OF INCOME
ACTUAL 4TH QUARTER 2004 vs 2003
In U.S. Dollars Thousands

ACTUAL ACTUAL BETTER/ ACTUAL YEAR ACTUAL YEAR BETTER/
4TH QTR 2004 4TH QTR 2003 (WORSE) 2004 2003 (WORSE)
$ % $ % $ % $ % $ % $ %

Revenue:
Online Services 13,705 45 13,588 52 117 1 54,487 50 53,520 57 967 2
Other Media Services 11,070 37 10,583 40 487 5 40,690 37 36,778 39 3,913 11
Exhibitions 5,379 18 1,965 7 3,414 174 13,015 12 3,327 3 9,688 291
Miscellaneous 132 0 148 1 (16) (11) 512 1 657 1 (145) (22)

Total Revenue (Gross) 30,286 100 26,284 100 4,002 15 108,704 100 94,282 100 14,422 15
Discount Allowed 761 3 645 2 (116) (18) 2,858 3 2,613 3 (245) (9)

Total Revenue (Net) 29,525 97 25,639 98 3,886 15 105,846 97 91,669 97 14,177 15
Sales costs 7,239 24 8,286 32 1,048 13 29,956 28 30,113 32 157 1
Contribution Margin 22,286 74 17,353 66 4,933 28 75,890 70 61,556 65 14,334 23
Operating Expenses:
Event Production Costs 1,836 6 602 2 (1,234) (205) 3,774 39 30 1 (2,844) (306)
Community Costs 5,532 18 3,428 13 (2,104) (61) 16,967 16 12,331 13 (4,636) (38)
General & Administration
Costs 8,023 26 7,641 29 (382) (5) 31,252 29 28,682 30 (2,570) (9)
Online Development Costs 1,126 4 1,072 4 (54) (5) 4,232 4 4,960 5 728 15
Non-cash Compensation 876 3 206 1 (670) (326) 2,117 2 1,419 2 (698) (49)
Amortization 373 1 920 4 547 59 1,480 1 4,453 5 2,973 67

Total Operating Expenses 17,766 59 13,869 53 (3,897) (28) 59,822 54 52,775 56 (7,047) (13)
Income from Operation 4,520 15 3,484 13 1,036 301 6,068 16 8,781 9 7,287 83
Interest income 83 0 49 0 34 72 219 0 122 0 97 80
Gain/(losses)on sales of
available-
for-sale securities 530 2 (40) (0) 570 1412 1,120 1 (40) (0) 1,160 2,873
Foreign exchange
gains/(losses), net 302 1 (102) (0) 404 396 240 0 0 0 240 100

Income before Income Taxes 5,435 18 3,391 13 2,044 60 17,647 16 8,863 9 8,784 99
Income Tax Provision (45) (0) (343) (1) 298 87 (651) (1) (668) (1) 17 3
Net Income before minority
interest 5,390 18 3,048 12 2,342 77 16,996 16 8,195 8 8,801 107
Minority interest (389) (1) (392) (1) 3 1 (1,227) (1) (861) (1) (366) (43)
Net Income 5,001 17 2,656 11 2,345 88 15,769 14 7,334 78,43 51 15
EBITDA excluding non-cash
compensation 6,451 21 5,347 20 1,104 21 22,237 20 18,709 20 3,528 19