[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,]
