Mr. Enrique T. Espeleta

January 25, 1980 Mr. Enrique T. Espeleta Corporate Secretary, Jade International Co., Inc. Avenue B, Bataan Export Processing Zone Mariveles, Bataan Dear Mr. Espeleta: This has reference to your letter of 11 December 1979, requesting authority from this Commission to issue certificates of stock to the members of the board of directors of Jade International Co., Inc. prcd It appears that in the past increases of capital stock of said corporation from P500,000.00 to P7,500,000.00 and from P7,500,000.00 to P20,000,000.00 approved on 7 June 1976 and 17 December 1976, respectively, Mr. Howard (Tao On) Lo paid for the subscriptions of certain stockholders as evidenced by the deeds of assignment dated 26 April 1976 and 3 December 1976, on file with the records of this Commission. At the first increase of capital stock, Mr. Lo paid in full the subscriptions of said stockholders while at the subsequent increase, he paid partially their subscriptions. In a deed of assignment supposedly executed by 9 of said stockholders (except Ruperto Kapunan III) dated 26 July 1978 and a separate deed of assignment executed by Allan Grodeu, they transferred all their shares of stock including their unpaid subscriptions in favor of Mr. Lo. While your letter states that Mr. Lo has acquired the shares of stock of Mr. Kapunan, it appears that the latter did not sign the deed of assignment dated 26 July 1978. On the other hand, a bill of sale executed on June 10, 1976 by Howard (Tao On) Lo transferring to Ruperto S. Kapunan III 15,000 shares worth P1,500,000.00 has been filed with our records. An explanation, therefore, is requested on this matter. Meanwhile, that we are not clarified of the transfers made by the persons involved, we can not take final action on your request. Very truly yours, (SGD.) ROSARIO N. LOPEZ Director Corporate and Legal Department