DeHeng Chen Chan, LLC
225 Broadway, Suite 1910
New York, NY 10007
Tel: (212) 608-6500
Fax: (212) 608-9050
Sender's e-mail: wpaul@dcclaw.com
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February 10, 2006
Ms. Babette Cooper
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: STRONG TECHNICAL INC.
ITEM 4.01 FORM 8-K DATED JANUARY 30, 2006
(FILED FEBRUARY 2, 2006)
FILE NO. 333-112111
Dear Ms. Cooper:
This letter is submitted on behalf of Strong Technical Inc. (the
"Company"), in response to the comment letter of the Staff of the Division of
Corporation Finance of the Securities and Exchange Commission dated February 9,
2006 (the "Staff Letter") regarding the disclosure under Item 4.01 in the
Company Current Report on Form 8-K dated January 30, 2006 and filed on February
2, 2006 (File No. 333-112111). The Company is filing today Amendment No.1 to
Form 8-K on Form 8-K/A with revised disclosure in response to the comments in
the Staff Letter as discussed below.
Our numbered responses below correlate to the numbers in the Staff
Letter, and we have provided the text of the comments included in the Staff
Letter for convenience purposes.
1. IN THE FORM 8-K FILED FEBRUARY 2, 2006, WE NOTE THE AUDIT REPORT DATED
AUGUST 8, 2005 BY CHILD, SULLIVAN AND COMPANY. WE ALSO NOTE THE REVIEW
REPORT DATED JANUARY 19, 2006 BY CHILD, VAN WAGONER AND BRADSHAW PLLC.
IT THUS APPEARS THAT CHILD, SULLIVAN AND COMPANY HAS MERGED WITH ANOTHER
FIRM. THIS IS CONSIDERED A CHANGE IN ACCOUNTANTS. ACCORDINGLY, A FORM
8-K NEEDS TO BE FILED IN ACCORDANCE WITH ITEM 304 OF REGULATION S-B TO
RECOGNIZE THE CHANGE IN ACCOUNTANTS.
On or around January 2, 2006, Child, Sullivan & Company, the principal
accountant for Henan Zhongpin Food Share Co., Ltd. (a predecessor in interest to
Strong Technical Inc.) changed its accounting practice from a corporation to a
professional limited liability company named Child, Van Wagoner & Bradshaw,
PLLC.
We understand that this is viewed as a change in accountants so the Company has
revised its previous disclosure under Item 4.01 in the Company's Current Report
on Form 8-K dated January 30, 2006 and filed on February 2, 2006 (File No.
333-112111), to include disclosure relating to this change of accountants and
the circumstances relating to such change, as of January 30, 2006. A separate
letter from Child, Sullivan & Company is also attached to Amendment No.1 to Form
8-K on Form 8-K/A.
2. INCLUDE A LETTER FROM SHERB & CO., LLP ADDRESSING YOUR DISCLOSURE IN
YOUR FORM 8-K FILED FEBRUARY 2, 2006 AS AN EXHIBIT TO YOUR FORM 8-K/A.
We note the Staff's comment and Amendment No.1 to Form 8-K on Form 8-K/A
being filed contains a letter from Sherb & Co., LLP.
In connection with responding to your comments, the Company acknowledges
the following:
|X| The Company is responsible for the adequacy and accuracy of the
disclosure in the filing;
|X| 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
|X| 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.
Sincerely,
/s/ Wesley J. Paul
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Wesley J. Paul
cc: Zhu Xianfu
Xiaomin Chen, Esq.