0001078782-12-003156.txt : 20130125 0001078782-12-003156.hdr.sgml : 20130125 20121214135434 ACCESSION NUMBER: 0001078782-12-003156 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20121214 FILER: COMPANY DATA: COMPANY CONFORMED NAME: US-BLH BIO-ENGINEERING INT'L, INC. CENTRAL INDEX KEY: 0001547021 STANDARD INDUSTRIAL CLASSIFICATION: CONSTRUCTION MACHINERY & EQUIP [3531] IRS NUMBER: 452724562 STATE OF INCORPORATION: CA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 699 SERRAMONTE BLVD., STE 212 CITY: DALY CITY STATE: CA ZIP: 94015 BUSINESS PHONE: 650-530-0699 MAIL ADDRESS: STREET 1: 699 SERRAMONTE BLVD., STE 212 CITY: DALY CITY STATE: CA ZIP: 94015 CORRESP 1 filename1.htm SEC Response

December 13, 2012


Amanda Ravitz

Assistant Director

Mary Beth Breslin

Louis Rambo

United States

Securities and Exchange Commission

Washington, D.C. 20549


Re:

US-BLH Bio-Engineering Int’l, Inc.

Amendment No. 4 to Registration Statement on Form S-1

Filed December 10, 2012

File No. 333-181341


Dear Ms. Ravitz;


Please find below the Company’s responses to your comment letter of December 12, 2012.


Unaudited Financial Statements, page F-14


Notes to Unaudited Financial Statements, page F-18


1. We note your response to prior comment 6 and, additionally, that your outstanding related party notes payable appear to be significant to your total outstanding liabilities as of September 30, 2012. We further note from your response that you relied upon the guidance in Instruction 1 to Item 404(a) of Regulation S-K to remove the reference to Monica Dong, who is a related party. However, the guidance in the FASB Accounting Standards Codification is applicable to financial statements. As previously requested, please revise your filing to label this notes payable outstanding as of September 30, 2012 as a related party note payable and to provide the disclosures for your related party loans pursuant to the guidance in 850-10-50 and 470-10-50 of the FASB Accounting Standards Codification.


Related party disclosure has been re added to the Notes to the Unaudited Financial Statements and expanded.



Very truly yours,


/s/ Guozhi Wang   

Guozhi Wang

President, Chief Executive Officer and Chairman of the Board

US-BLH Bio-Engineering Int’l, Inc.