DAVIS & ASSOCIATES
(A PROFESSIONAL LAW CORPORATION)
-SECURITIES, BUSINESS & INTERNATIONAL LAWYERS-
LOS ANGELES NEWPORT BEACH
IRVINE SANTA MONICA
HONG KONG SWITZERLAND
Ritz Carlton Annex
(213) 400-200/ (310) 823-8300
fax (310) 301-3370
Respond To:
P.O. Box 12009
Marina Del Rey, CA
90295-3009
Don@securities-attys.com
January 8, 2012
Justin Dobbie
Legal Branch Chief
Tonya K Aldave
Staff Attorney
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, NE
Washington, DC 20549
Re: JuQun, Inc.
Amendment No. 3 to Form 10-12G Registration Statement
Filed January 8, 2012
File No. 000-54823
Dear Mr. Dobble,
We have been employed by JuQun, Inc (the Company), to represent them in connection with this Amendment No. 3 to their Form 10-12G filing.
I am responding to your letter of comments dated January 2, 2013. Amendment No 3 to the registration statement has just been filed.
I believe the Company has now complied with all of the SECs comments set forth in your most current comment letter. We have filed the marked version as well to show the changes.
If you desire more information or have questions, please contact me direct on my cell phone at 213 400 2007.
We appreciate your assistance in this matter.
Very Truly Yours,
/s/
Donald G. Davis