June 8, 2007
Via Facsimile, EDGAR and Mail
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Ms. Kristin Lochhead, Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549
Re: Bonso Electronics International Inc.
Dear Ms. Lochhead:
This letter is in response to your letter dated May 25, 2007 ("Letter"),
which relates to the Form 6-K for the Third Quarter ended December 31, 2006,
filed on March 13, 2007 with the United States Securities and Exchange
Commission ("SEC"). The responses below have been numbered to correspond to the
numbering used in the Letter.
Consolidated Balance Sheet, page 3
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1. In future filings, please remove the heading "audited" from the
balance sheet, as full audited financial statements as required by
U.S. GAAP are not provided.
Bonso's management has reviewed this comment and will address the comment
in its future filings.
Consolidated Income Statement, page 5
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2. We see that you incurred net losses in the three month periods ended
December 31, 2006 and 2005. Under SFAS 128 you should not increase
basic weighted average shares for potentially dilutive securities when
the effect is anti-dilutive. In future filings, please exclude
anit-dilutive instruments from earnings per share calculations in
periods when the affect is anti-dilutive.
Bonso's management has reviewed this comment and will address the comment
in its future filings.
Ms. Kristin Lochhead, Staff Accountant
Division of Corporation Finance
United States Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549
Three month period ended December 31, 2006 compared to the three month
period ended December 31, 2005, page 7
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Other income, page 8,
3. We reference the disclosure that the other income (loss) during the
three months ended December 31, 2005 was caused by the
"reclassification of scrape sale for disclosure purposes." Please tell
us how you are accounting for scrape sales and the nature of the
reclassification for disclosure purposes.
The reclassification is to response to your comment #1 as stated in your
letter dated March 15, 2005. In our response to you dated April 15, 2005,
we have considered your Comment and believe that the sales of scrape
materials should have been classified as operating income. Since then, we
have classified all scrape sale as operating income.
We understand that:
o Bonso is responsible for the adequacy and accuracy of the disclosure
in the filings;
o Staff comments or changes to disclosure in response to staff comments
in the filings reviewed by the Staff do not foreclose the Commission
from taking any action with respect to the filing; and
o Bonso 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.
If you have any questions or wish to discuss anything further, please do not
hesitate to contact the undersigned.
Very truly yours
/s/ Cathy Kit Teng Pang
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Cathy Kit Teng Pang
CFO