[January 27, 2010 F. Alec Orudjev Direct Phone (202) 912-4842 Direct Fax (202) 912-4830 aorudjev@cozen.com Division of Corporation Finance 100 F Street, N.E. Re: Dear Mr. Brown: Again, thank you for all your help and guidance throughout the review process. Sincerely, COZEN O'CONNOR Enclosures Cc: Ralph V. De Martino, Esq.]
[CUSIP No. G6647N108 1 NAMES OF REPORTING PERSONS 2 CHECK THE APPROPRIATE BOX IF A MEMBER OF A (SEE INSTRUCTIONS) o (a) o (b) 3 SEC USE ONLY 4 CITIZENSHIP OR PLACE OF ORGANIZATION The British Virgin Islands 5 SOLE VOTING POWER NUMBER OF 13,805,809 ordinary shares. Beijing Tourism, the ultimate sole shareholder of Poly,] [Joint Filingreement [Remainder of this page has been left intentionally blank.] Poly Victory Investments Limited Yunxin Mei Chairman Beijing Tourism LIU Yi President c95060exv99wa.htm 2 EX-99.A]
[(Name of Issuer) Ordinary Shares/American Depositary Shares (Title of Class of Securities) 16938G 107 (CUSIP Number) December 31, 2009 (Date of Event Which Requires Filing of this Statement) ¨ ¨ x *The remainder of this cover page shall be filled out for a reporting person’s initial filing on this form with respect to the subject class of securities, and for]
[CUSIP No. G6647N108 1 NAMES OF REPORTING PERSONS 2 CHECK THE APPROPRIATE BOX IF A MEMBER OF A (SEE INSTRUCTIONS) o (a) o (b) 3 SEC USE ONLY 4 CITIZENSHIP OR PLACE OF ORGANIZATION The British Virgin Islands 5 SOLE VOTING POWER NUMBER OF 13,805,809 ordinary shares. Beijing Tourism, the ultimate sole shareholder of Poly,] [Joint Filingreement [Remainder of this page has been left intentionally blank.] Poly Victory Investments Limited Yunxin Mei Chairman Beijing Tourism LIU Yi President c95060exv99wa.htm 2 EX-99.A]
[CUSIP No. 16938G 107]
[CUSIP No. 16938G 107]
[dswl9.txt 1 13G/A]
[dswl9.txt 1 13G/A]
