CORRESP 1 filename1.txt September 26, 2006 TO: Ms. Kristi Beshears Staff Accountant Division of Corporate Finance Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549 CC: Mr. Daniel L. Gordan Branch Chief Division of Corporate Finance Securities and Exchange Commission 450 Fifth Street N.W. Washington, D.C. 20549 RE: CHINA FINANCE ONLINE CO. LIMITED FORM 20-F FOR THE YEAR ENDED DECEMBER 31, 2005 (FILE NO. 000-50975) Dear Ms. Beshears, I refer to your fax of September 21, 2006 to China Finance Online Co., Limited (the "Company") regarding SEC comments on the Company's Form 20-F filed on May 23, 2006 and our letter addressed to you through confidential submission via EDGAR dated September 7, 2006. The Company has been working with its accountants to prepare responses to your comments, and notes that October 1 to 7 is a national holiday period in China. The Company expects to provide responses to your comments via EDGAR by October 20, 2006. In the event that the Company will not be able to respond by October 20, the Company will contact you in advance. We appreciate your understanding. Please direct all future correspondence with respect to this matter to the Company as set forth below: China Finance Online Co. Limited 9th Floor of Tower C, Corporate Square No. 35 Financial Street Xicheng District, Beijing 100032 People's Republic of China Tel: +86 (10) 5832 5288 Fax: +86 (10) 5832 5200 Attention: Jun Wang With a copy to: [O'MELVENY & MYERS LLP LOGO] Ms. Kristi Beshears and Mr. Daniel L. Gordan, SEPTEMBER 26, 2006 - Page 2 O'Melveny & Myers LLP Plaza 66, 37th Floor 1266 Nanjing Road West Shanghai 200040 People's Republic of China Tel: +86 (21) 2307-7068 Fax: +86 (21) 2307-7300 Attention: Todd Bissett, Esq. I would appreciate your acknowledging receipt of the letter by emailing me at jwang@jrj.com. Thank you for your assistance in this matter. Very truly yours, /s/ Jun Wang --------------------------------- Jun Wang Chief Financial Officer China Finance Online Co. Limited cc: Howard Zhang, Esq. David Lin, Esq. Todd Bissett, Esq.