[January 27, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re: Agria Corporation Dear Mr. Reynolds and Mr. Archfield: For ease of review, we have set forth below each of the numbered comments of the Staffs letter and the Companys responses thereto. Item 5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57 1. Form 20-F or]
[January 27, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re: Agria Corporation Dear Mr. Reynolds and Mr. Archfield: For ease of review, we have set forth below each of the numbered comments of the Staffs letter and the Companys responses thereto. Item 5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57 1. Form 20-F or]
[January27, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re:riarporation Dear Mr.Reynolds and Mr.Archfield: For ease of review, we have set forth below each of the numberedmments of the Staffs letter and thempanys responses thereto. Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57]
[January27, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re:riarporation Dear Mr.Reynolds and Mr.Archfield: For ease of review, we have set forth below each of the numberedmments of the Staffs letter and thempanys responses thereto. Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57]
[January27, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re:riarporation Dear Mr.Reynolds and Mr.Archfield: For ease of review, we have set forth below each of the numberedmments of the Staffs letter and thempanys responses thereto. Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57]
[January27, 2011 VIA EDGAR AND FACSIMILE John Reynolds Re:riarporation Dear Mr.Reynolds and Mr.Archfield: For ease of review, we have set forth below each of the numberedmments of the Staffs letter and thempanys responses thereto. Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57]
[Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57 1. Form 20-F or explain to us why you believe such disclosure is not necessary. The Company respectfully advises the Staff that at the time the 20-F was filed, the Company had only entered into an agreement in principle for the]
[Item5. Operating and Financial Review and Prospects, page 40 D. Trend Information, page 57 1. Form 20-F or explain to us why you believe such disclosure is not necessary. The Company respectfully advises the Staff that at the time the 20-F was filed, the Company had only entered into an agreement in principle for the]
[January 27, 2011 Via Facsimile and EDGAR Assistant Director Division of Corporation Finance 100 F Street, N.E. Re: KongZhong Corporation Annual Report on Form 20-F for the Fiscal Year ended December 31, 2009 filed on June 4, 2010 (File No. 000-50826) Dear Mr. Spirgel: Mr. Larry Spirgel - - Sincerely,]
[January 27, 2011 Via Facsimile and EDGAR Assistant Director Division of Corporation Finance 100 F Street, N.E. Re: KongZhong Corporation Annual Report on Form 20-F for the Fiscal Year ended December 31, 2009 filed on June 4, 2010 (File No. 000-50826) Dear Mr. Spirgel: Mr. Larry Spirgel - - Sincerely,]
