CORRESP 3 filename3.htm
WILLIAMS LAW GROUP, P.A.
2503 W. Gardner Ct.
Tampa FL 33611
Phone:  813-831-9348
Fax:  813-832-5284
e-mail:  wmslaw@tampabay.rr.com

July 12, 2010

Ms. Barbara C. Jacobs
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. St., N.E.
Washington, D.C. 20549-7010

 
Re:
Hyperera, Inc.
Registration Statement on Form S-1
Amendment No. 4.
File No. 333-163035

Dear Ms. Jacobs:

We have filed on EDGAR the above Amendment No. 3 and the related response table which is attached to this letter.

Thank you for your consideration.

 
Sincerely,
   
 
/s/ MICHAEL T. WILLIAMS, ESQ.
   
 
Michael T. Williams, Esq.

 
 

 

Comment
Number
 
Explanation
1       .
 
Requested information added to Risk Factor, page 11.
2       .
 
Interest of Experts section revised to reflect years covered in financial statements, page 24.
3       .
 
Disclosure in MDA Overview as well as related Risk Factor revised as follows:
     
Risk Factors:
       
Our generating minimal revenues from operations makes it difficult for us to evaluate our future business prospects and make decisions based on those estimates of our future performance.
       
Although we have taken significant steps to develop our business plan since our inception, as of June 30, 2009, we have generated only minimal revenues.  Our business plan is still speculative and unproven.  There is no assurance that we will be successful in executing our business plan or that even if we successfully implement our business plan, we will ever generate significant revenues or profits, which makes it difficult to evaluate our business.  As a consequence, it is difficult, if not impossible, to forecast our future results based upon our historical data.  Because of the uncertainties related to our lack of historical operations, we may be hindered in our ability to anticipate and timely adapt to increases or decreases in sales, revenues or expenses.  If we make poor budgetary decisions as a result of unreliable historical data, we may never generate revenues or become profitable or incur losses, which may result in a decline in our stock price. 
     
MDA
       
Overview
       
Our business is sale of hardware and software and customization of clinical information system software for medical clinics and hospitals in China and throughout Asia.   We have been developing our infrastructure to begin to sell the clinical information system software and have generated only minimal sales and revenues as of June 2010.
     
4       .
 
“Total” Column in Compensation Table completed and compensation revised.
 
 
 

 

5       .
 
Accounting disclosures were updated to reflect the new FASB Standard Codification became effective on July 1, 2009.  All the references to accounting standards were revised and fixed accordingly.   See updated accounting disclosures below

Financial Statements

Notes to the Financial Statements

5.  Accounting disclosures were updated to reflect the new FASB Standard Codification became effective on July 1, 2009.  All the references to accounting standards were revised and fixed accordingly.

Recent Issued Accounting Pronouncements

The following pronouncements have become effective during the period covered by these financial statements or will become effective after the end of the period covered by these financial statements:

Pronouncement
 
Issued
 
Title
         
ASC 855
 
May 2009
 
Subsequent Events
ASC 105
 
June 2009
 
The FASB Accounting Standards Codification and the Hierarchy of Generally Accepted Accounting Principles—a replacement of FASB Statement No. 162
ASC 820
 
August 2009
 
Fair Value Measurements and Disclosures – Measuring Liabilities at Fair Value
ASC 260
 
September 2009
 
Earnings per Share – Amendments to Section 260-10-S99
ASC 820
 
September 2009
 
Investments in Certain Entities that Calculate Net Asset Value per Share (or Its Equivalent)
ASC 605
 
October 2009
 
Revenue Recognition (Topic 605): Multiple-Deliverable Revenue Arrangements – a consensus of the FASB Emerging Issues Task Force
ASC 470
 
October 2009
 
Accounting for Own-Share Lending Arrangements in Contemplation of Convertible Debt Issuance or Other Financing – a consensus of the FASB Emerging Issues Task Force
ASC 860
 
December 2009
 
Transfers and Servicing (Topic 860): Accounting for Transfers of Financial Assets
 
 
 

 
 
ASC 505
 
January 2010
 
Accounting for Distributions to Shareholders with Components of Stock and Cash – a consensus of the FASB Emerging Issues Task Force
ASC 810
 
January 2010
 
Consolidation (Topic 810): Accounting and Reporting for Decreases in Ownership of a Subsidiary – a Scope Clarification
ASC 718
 
January 2010
 
Compensation – Stock Compensation (Topic 718): Escrowed Share Arrangements and the Presumption of Compensation
ASC 820
 
January 2010
 
Fair Value Measurements and Disclosures (Topic 820): Improving Disclosures about Fair Value Measurements
ASC 855
 
February 2010
 
Subsequent Events (Topic 855): Amendments to Certain Recognition and Disclosure Requirements
ASC 810
 
February 2010
 
Consolidation (Topic 810): Amendments for Certain Investment Funds
ASC 815
  
March 2010
  
Derivatives and Hedging (Topic 815): Scope Exception Related to Embedded Credit Derivatives
         

Management assessed that the new accounting pronouncements listed above will not have a material impact on our financial statements.  The Company shall adopt the ASC 605 for revenue recognition of multiple elements arrangement for sales of customized information system software.