Xiangtian (USA) Air Power Co., Ltd.
c/o Luck Sky International Holdings Limited
Unit 602 Causeway Bay Comm Bldg 1
Sugar Street, Causeway Bay
Hong Kong, People’s Republic of China
April 29, 2015
Kevin Vaughn
Accounting Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street NE
Washington, DC 20549
Re: | Xiangtian (USA) Air Power Co., Ltd. |
Form 10-K for the fiscal year ended July 31, 2014 Filed November 20, 2014
Form 10-Q for the quarterly period ended October 31, 2014 Filed December 18, 2014
File No. 000-54520
Dear Mr. Vaughn:
In response to your letter of March 12, 2015, Xiangtian (USA) Air Power Co., Ltd. (the “Company”), acknowledges that:
1. | The Company is responsible for the adequacy and accuracy of the disclosure in the filing; |
2. | Staff comments or changes to disclosure in response to staff comments do not foreclose the commission from taking any action with respect to the filing; and |
3. | The Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Very truly yours, | |
/s/ Zhiqi Zhang | |
Zhiqi Zhang, Chief Executive Officer |