[January 14, 2009 Ms. Kathleen Collins, One Station Place, Re: KongZhong Corporation 2007 (File No. 000-50826) Annual Report on Form 20-F for the Fiscal Year ended December 31, Dear Ms. Collins: Staff Company 2007 Form 20-F For your convenience, the Company has included the Staff’s comments in this response letter in italicized form and keyed its responses accordingly. The Company’s]