THE LAW OFFICE OF
CONRAD
C. LYSIAK
601
West First Avenue, Suite 903
Spokane,
Washington 99201
(509) 624-1475
FAX:
(509) 747-1770
EMAIL:
cclysiak@lysiaklaw.com
August 4,
2009
Ms.
Maryse Mills-Apenteng, Esq.
Special
Counsel
Securities
and Exchange Commission
100 F
Street, N.E.
Washington,
D.C. 20549-4561
|
|
RE:
|
Multiplayer
Online Dragon, Inc.
|
|
|
|
Form
S-1 Registration Statement
|
|
|
|
File
No. 333-159896
|
Dear Ms.
Mills-Apenteng:
In
response to your letter of comments dated July 8, 2009, please be advised as
follows:
General
1. The disclosure has been revised as
requested.
Cover
Page
2. The
corrections have been made.
Summary
of Our Offering
3. Disclosure
of the going concern opinion has been provided.
4. The disclosure has been revised to state that the Company has no
current or historical operations, and that the current business plan is to
design, host, and market collaborative Internet search communications
systems.
Risk
Factors
5. A
risk factor has been added disclosing the conflict of interest.
6. Disclosure has been provided that the Company has no operations or
product.
7. Reference to Microsoft and Yahoo has been
deleted.
|
|
Ms.
Maryse Mills-Apenteng, Esq.
|
|
|
Legal
Branch Chief
|
|
|
Securities
and Exchange Commission
|
|
|
RE:
|
Multiplayer
Online Dragon, Inc.
|
|
|
|
Form
S-1 Registration Statement
|
|
|
|
File
No. 333-159896
|
|
|
August
4, 2009
|
|
|
Page
2
|
8. We
acknowledge the confusion in the language and have revised to clarify the
same.
9. The opinion is that of the Company. As you know this
information is common knowledge and permeates just about every SEC filing
relating to doing business in China. No consent is required as a
matter of law.
Plan
of Distribution; Terms of the Offering
10. The requested language has been
provided.
Management’s
Discussion and Analysis or Plan of Operation
11. The information requested has been
provided.
Business
12. Disclosure
of the target/market users has been provided. Specifically, we do not
know why Internet users would choose the Company search engine over established
search engines. You would have to inquire of the
users. We know people will use the Company’s search engine merely
because it is there.
13. The disclosure requested has been
provided.
14. The statistics have been deleted. Supplementally, you
can Google the matter and the statistics appear.
15. The disclosure in the accounting about a Vancouver office was
incorrect and has been deleted.
Undertakings
16. The undertakings have been revised as
requested.
|
|
Yours
truly,
|
|
|
|
|
The
Law Office of Conrad C. Lysiak, P.S.
|
|
|
|
|
BY:
|
CONRAD
C. LYSIAK
|
|
|
|
Conrad
C. Lysiak
|
CCL:hdw
cc:
Multiplayer Online Dragon, Inc.