0001549727-13-000101.txt : 20130702 0001549727-13-000101.hdr.sgml : 20130702 20130522130614 ACCESSION NUMBER: 0001549727-13-000101 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20130522 FILER: COMPANY DATA: COMPANY CONFORMED NAME: China Xibolun Technology Holdings Corp CENTRAL INDEX KEY: 0001479382 STANDARD INDUSTRIAL CLASSIFICATION: SERVICES-MANAGEMENT CONSULTING SERVICES [8742] IRS NUMBER: 271179591 STATE OF INCORPORATION: NV FISCAL YEAR END: 0430 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: NO.587, 15TH ROAD, 3RD AVENUE STREET 2: BINHAI INDUSTRIAL PARK, ECO & TECH ZONE CITY: WENZHOU STATE: F4 ZIP: 325088 BUSINESS PHONE: 8613909840703 MAIL ADDRESS: STREET 1: NO.587, 15TH ROAD, 3RD AVENUE STREET 2: BINHAI INDUSTRIAL PARK, ECO & TECH ZONE CITY: WENZHOU STATE: F4 ZIP: 325088 FORMER COMPANY: FORMER CONFORMED NAME: Dimus Partners Inc. DATE OF NAME CHANGE: 20091223 CORRESP 1 filename1.htm Management<font style="font-family:Arial Unicode MS,Times New Roman">’</font>s Report on Internal Control over Financial Reporting

May 22, 2013


Tom Kluck

Branch Chief

Division of Corporation Finance  


Re:

Response to comment letter dated February 22, 2013

China Xibolun Technology Holdings Corporation

Form 10-K for the fiscal year ended April 30, 2012

Filed July 25, 2012

File No. 000-54539



Item 7.

Management's Discussion and Analysis or Plan of Operation


Plan of Operations, page 22


1.

In future Exchange Act periodic reports, please specifically discuss the steps you have taken to implement your business plan. If no steps have been taken, please affirmatively state.


Response:  In future Exchange Act periodic reports, we will specifically discuss the steps we have taken to implement our business plan or we will affirmatively state that no steps have been taken.  


 

2.

Please revise your disclosure in this section in future Exchange Act periodic reports to describe in greater detail the company’s plan of operation for the next fiscal year. Please provide details of your specific plan of operation, including detailed milestones, the anticipated time frame for beginning and completing each milestone, categories of expenditures and the expected sources of such funding. Also, explain how the company intends to meet each of the milestones if it cannot receive funding.


Response:  In future filings, we will revise our disclosure in this section to describe in greater detail the company’s plan of operation for the next fiscal year.   We will provide details of our specific plan of operation, including detailed milestones, the anticipated time frame for beginning and completing each milestone, categories of expenditures and the expected sources of such funding.   We will explain how the company intends to meet each of the milestones if it cannot receive funding.



Acknowledgement Statement


In connection to responding to all the comments of the Securities and Exchange Commission, China Xibolun Technology Holdings Corporation (“Company”) hereby acknowledges that:


1. The Company is responsible for the adequacy and accuracy of the disclosure in the filings;


2. Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and


3. 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.


If you have any questions or comments regarding the foregoing, please do not hesitate to contact us via electronic mail: chinyk@163.com, also with copy to our legal counsel’s office at Bernard & Yam, LLP, Attn: Man Yam, Esq., 401 Broadway Suite 1708, New York, NY 10013, phone: 212-219-7783, facsimile: 212-219-3604, manbylaw@gmail.com.


Truly yours



   /s/ Chin Yung Kong

_________________________   

        Chin Yung Kong


Chief Executive Officer

Chief Financial Officer


China Xibolun Technology Holdings Corporation