VENTURA ASSETS LIMITED
2241 Flintridge Drive
Glendale, California 91206
Telephone: (818) 424-0219
June 19, 2008
M. Mark P. Shuman, Branch Chief
United States Securities and Exchange Commission
Washington, D.C. 20549
Att. Matthew Crispino, Esq.
Dear Mr. Shuman:
Re: Ventura Assets Limited
Amendment No. 1
Registration Statement on Form 10
Filed on June 13, 2008
File No. 000-53186
Thank you for your letter of June 18, 2008 to which we hereby respond.
We have today filed Amendment No. 2 to the above captioned Registration
Statement. This amendment, we believe, fully addresses the issues of your
letter. Additionally, we will address the issues of your letter in the order as
they appeared.
Comment:
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Form 10
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Audited Financial Statements of Ventura Assets, Ltd.
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1. We note that your response to comment one of our letter dated May 19, 2008.
Please revise your statement of Operations and Statement of Cash Flows to
include information for the three months ended March 31, 2007 as well as
cumulative information from your company's inception through March 31, 2008. See
the introductory paragraph and paragraph (b)(6) of Item 80-03 of Rebulation S-X.
Also, it appeared that you have not made any changes to the footnotes to your
financial statements. Please confirm that inclusion of first quarter 2008
financial information in your financial statements does not require any new
revised footnote disclosure. See Item 8-03(b)(1) of Regulation S-X
Answer: The financials have been up-dated as follows:
Statement of Cash Flows:
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1) A column has been added to the left side of the "1st QTR, 3/31/2008", called
"lst QTR, 3/31/2007.
2) The last column's heading has been amended to read: "Inception to March 31,
2008" in lieu of "Inception to Dec. 2007".
Statement of Operations:
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1) A column has been added to the left side of the "1st QTR, 3/31/2008", headed
"lst QTR, 3/31/2007".
2) The last column's heading has been changed from "Inception to Dec. 2007" to
read "Inception to March 2008".
Notes to Financial Statements:
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There are no changes to the "Notes to Financial Statements", except the
following dates:
1) On page F-7, the paragraph before the heading "Income Taxes", "through
December 2007" has been changed to "through March 31, 2008".
2) On the page F-7 under the heading "Earnings Per Common Share" lst
paragraph, the last line, "December 2007", has been changed to "March 31, 2008".
3) On page F-8, under the heading of "Going Concern", middle of the third
line, "As of December 31, 2006" has been changed to "March 31, 2008".
4) On page F-11, under the heading "Note 5 - Income Taxes", the last sentence,
"through December 31, 2007", has been changed to "through March 31, 2008".
We believe that the responses set forth herein adequately addresses your
comments. If this is not the case, will you be so kind as to contact us at your
earliest convenience for any further issues. We would like to fully comply with
your comments in a time sensitive manner.
Yours truly,
/s/ Hasmik Yaghobyan
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Hasmik Yaghobyan
Chief Financial Officer and Director
Ventura Assets Limited