Techs Loanstar, Inc.
319 Clematis Street, Suite 703
West Palm Beach, Florida 33401
Telephone (561) 514-9042
Facsimile (561) 514-9046
May 4, 2011
Mr. Jorge Bonilla
Securities and Exchange Commission
Washington, D.C. 20549
Re: Techs Loanstar, Inc.
Form 10-K for the year ended April 30, 2010
Forms 10-Q for the quarters ended July 31, 2010, October 31, 2010 and January 31, 2011
File No. 333-143630
Dear Mr. Bonilla:
We are in receipt of your letter dated March 24, 2011 regarding our Form 10-K for the year ended April 30, 2010 and Forms 10-Q's for the quarters ended July 31, 2010, October 31, 2010 and January 31, 2011. Please see our responses below; we have numbered them to correspond with your comments.
General
1. We will file the amendments within five (5) business days of confirmation that we have satisfied your comments in number 2 below.
Form 10-K
2. In the determination of the accounting acquirer in the merger of the two non public companies ZenZuu USA, Inc., ("ZZUSA") and ZZPartners, Inc. ("ZZP"), management considered that it was the business of ZZP that was the go forward business of ZZUSA and therefore was considered the accounting acquirer. Additionally, subsequent to the merger, the shareholders of ZZP controlled ZZUSA. ZZUSA was formed immediately prior to the merger, and accordingly there was no relationship between the companies before the merger.
We have adjusted the accumulated deficit in the Statements of Changes in Stockholders' deficit to include the historical losses of ZZP.
We acknowledge that:
Sincerely,
Barry Hollander, Chief Financial Officer