[Division of Corporation Finance Station Place 100 F Street, N.E. Attn: Claire Erlanger Re: China Automotive Systems, Inc. (the “Company”) Form 10-K for the year ended December 31, 2008 Filed March 26, 2009 File No. 000-33123 Dear Ms. Erlanger: For your convenience, we have repeated comments from the Staff’s December 22, 2009 letter immediately prior to our response below. From]
[Division of Corporation Finance Station Place 100 F Street, N.E. Attn: Claire Erlanger Re: China Automotive Systems, Inc. (the “Company”) Form 10-K for the year ended December 31, 2008 Filed March 26, 2009 File No. 000-33123 Dear Ms. Erlanger: For your convenience, we have repeated comments from the Staff’s December 22, 2009 letter immediately prior to our response below. From]
[FORM S-3 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 SORL Auto Parts, Inc. Delaware 30-0091294 (State or other jurisdiction (I.R.S. Employer of incorporation or organization) Identification Number) No. 1169 Yumeng Road Ruian Economic Development District Ruian City, Zhejiang Province People’s Republic of China 86-577-65817720 (Address, including zip code, and telephone number, Xiaoping Zhang Chief Executive Officer No. 1169 Yumeng] [EX-4.1 2 v169999_ex4-1.htm] [SORL AUTO PARTS, Inc. TO [ ] Trustee Indenture Dated as of __, 200_ TABLE OF CONTENTS Page ARTICLE I DEFINITIONS AND OTHER PROVISIONS OF GENERAL APPLICATION Section 101. Definitions 1 Section 102. Compliance Certificates and Opinions 9 Section 103. Form of Documents Delivered to Trustee 9 Section 104. Acts of Holders 10 Section 105.] [EX-5.1 5 v169999_ex5-1.htm] [RATIOS OF EARNINGS TO COMBINED FIXED CHARGES AND PREFERRED DIVIDENDS Detail Calculation in accordance with Reg S-K Item 503(d) Nine Months ended September 30, Year Ended December 31, 2009 2008 2007 2006 2005 2004 Earnings: Income (loss) before income taxes and noncontrolling interests $ 10,613,846 15,338,593 12,587,522] [EX-23.1 11 v169999_ex23-1.htm]
[FORM S-3 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 SORL Auto Parts, Inc. Delaware 30-0091294 (State or other jurisdiction (I.R.S. Employer of incorporation or organization) Identification Number) No. 1169 Yumeng Road Ruian Economic Development District Ruian City, Zhejiang Province People’s Republic of China 86-577-65817720 (Address, including zip code, and telephone number, Xiaoping Zhang Chief Executive Officer No. 1169 Yumeng] [EX-4.1 2 v169999_ex4-1.htm] [SORL AUTO PARTS, Inc. TO [ ] Trustee Indenture Dated as of __, 200_ TABLE OF CONTENTS Page ARTICLE I DEFINITIONS AND OTHER PROVISIONS OF GENERAL APPLICATION Section 101. Definitions 1 Section 102. Compliance Certificates and Opinions 9 Section 103. Form of Documents Delivered to Trustee 9 Section 104. Acts of Holders 10 Section 105.] [EX-5.1 5 v169999_ex5-1.htm] [RATIOS OF EARNINGS TO COMBINED FIXED CHARGES AND PREFERRED DIVIDENDS Detail Calculation in accordance with Reg S-K Item 503(d) Nine Months ended September 30, Year Ended December 31, 2009 2008 2007 2006 2005 2004 Earnings: Income (loss) before income taxes and noncontrolling interests $ 10,613,846 15,338,593 12,587,522] [EX-23.1 11 v169999_ex23-1.htm]
