Initial Decision Release No. 1320

Administrative Proceeding

File No. 3-18082

UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

In the Matter of

CNK Global, Inc. (a/k/a American 

Life Holding Co., Inc.)

Initial Decision of Default

November 29, 2018

Appearances: James Carlson and David S. Frye for the Division of 

Enforcement, Securities and Exchange Commission

Before: Cameron Elliot, Administrative Law Judge

SUMMARY

This initial decision revokes the registration of the registered securities 

of Respondent CNK Global, Inc. (a/k/a American Life Holding Co., Inc.) due to 

its failure to timely file required periodic reports with the Securities and 

Exchange Commission.

INTRODUCTION

On July 27, 2017, the Commission issued an order instituting 

proceedings (OIP) pursuant to Section 12(j) of the Securities Exchange Act of 

1934. The OIP alleges that Respondent has a class of securities registered 

with the Commission pursuant to Exchange Act Section 12(g) and is 

delinquent in its periodic filings. 

A different administrative law judge was originally assigned to this 

proceeding and issued an initial decision of default against Respondent. CNK 

Glob., Inc., Initial Decision Release No. 1175, 2017 SEC LEXIS 2815 (ALJ 

Sept. 12, 2017). The Commission vacated that decision following the 

Supreme Court’s decision in Lucia v. SEC, 138 S. Ct. 2044 (2018); see 

Pending Admin. Proc., Securities Act of 1933 Release No. 10536, 2018 SEC 

LEXIS 2058, at *2-3 (Aug. 22, 2018). The matter was then reassigned to me 
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to provide Respondent with the opportunity for a new hearing. Pending 

Admin. Proc., Admin. Proc. Rulings Release No. 5955, 2018 SEC LEXIS 2264, 

at *2-3 (ALJ Sept. 12, 2018). Respondent was directed to submit a proposal 

for the conduct of further proceedings. CNK Glob., Inc., Admin. Proc. Rulings 

Release No. 5996, 2018 SEC LEXIS 2414 (ALJ Sept. 18, 2018). It did not 

submit a proposal. I have therefore proceeded under the Commission’s 

directive to not give weight to or otherwise presume the correctness of any 

prior opinions, orders, or rulings issued by the prior administrative law 

judge. Pending Admin. Proc., 2018 SEC LEXIS 2058, at *4.

Previously, I independently reviewed the evidence submitted by the 

Division and determined that Respondent was served with the OIP on July 

31, 2017. CNK Glob., Inc., Admin. Proc. Rulings Release No. 6276, 2018 SEC 

LEXIS 3039 (ALJ Nov. 1, 2018). Because Respondent failed to timely 

answer, I ordered it to show cause why the registration of its securities 

should not be revoked by default due to its failure to file an answer or 

otherwise defend this proceeding. Id. To date, Respondent has failed to

answer, submit a proposal for the conduct of further proceedings, respond to 

the show cause order, or otherwise defend this proceeding.

FINDINGS OF FACT

Respondent is in default for failing to file an answer, file a proposal for 

the conduct of further proceedings, or otherwise defend the proceeding. See

OIP at 2; 17 C.F.R. §§ 201.155(a)(2), .220(f); Pending Admin. Proc., 2018 SEC 

LEXIS 2058, at *4. Accordingly, as authorized by Rule of Practice 155(a), 17 

C.F.R. § 201.155(a), I find the following allegations in the OIP to be true.

CNK Global, Central Index Key No. 1187449 and ticker symbol ALFE, is 

a dissolved Florida corporation located in Seoul, South Korea, with a class of 

securities registered with the Commission pursuant to Exchange Act Section 

12(g). The company is delinquent in its periodic filings with the Commission, 

having not filed any periodic reports since it filed a Form 10-Q for the period 

ended June 30, 2014, which reported a net loss of $31,522 for the prior six 

months. As of July 25, 2017, the company’s common stock was quoted on 

OTC Link operated by OTC Markets Group, Inc., had two market makers,

and was eligible for the “piggyback” exception of Exchange Act Rule 15c2-

11(f)(3).

In addition to its repeated failures to timely file periodic reports, 

Respondent failed to heed a delinquency letter sent to it by the Commission’s 

Division of Corporation Finance requesting compliance with its periodic filing 

obligations or, through its failures to maintain a valid address on file with 

the Commission as required by Commission rules, did not receive the letter.
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CONCLUSIONS OF LAW

Exchange Act Section 13(a) and the rules promulgated thereunder 

require issuers of securities registered pursuant to Exchange Act Section 12 

to file with the Commission current and accurate information in periodic 

reports. Specifically, Rule 13a-1 requires issuers to file annual reports, and 

Rule 13a-13 requires domestic issuers to file quarterly reports. See 17 C.F.R. 

§§ 240.13a-1, .13a-13. Compliance with these reporting requirements is

mandatory. America’s Sports Voice, Inc., Exchange Act Release No. 55511, 

2007 SEC LEXIS 1241, at *12 (Mar. 22, 2007), recons. denied, Exchange Act 

Release No. 55867, 2007 SEC LEXIS 1239 (June 6, 2007). Scienter is not 

required to establish violations of Exchange Act Section 13(a) and Rules 13a1 and 13a-13. See SEC v. McNulty, 137 F.3d 732, 740-41 (2d Cir. 1998); SEC 

v. Wills, 472 F. Supp. 1250, 1268 (D.D.C. 1978). Respondent failed to timely 

file periodic reports. As a result, Respondent violated Exchange Act Section 

13(a) and Rules 13a-1 and 13a-13.

SANCTION

Under Exchange Act Section 12(j), the Commission is authorized, “as it 

deems necessary or appropriate for the protection of investors,” to revoke the 

registration of a security or suspend its registration for a period not 

exceeding twelve months if it finds, after notice and an opportunity for 

hearing, that the issuer of the security has failed to comply with any 

provision of the Exchange Act or rules thereunder. In determining what 

sanctions will adequately protect investors, the Commission “consider[s], 

among other things, the seriousness of the issuer’s violations, the isolated or 

recurrent nature of the violations, the degree of culpability involved, the 

extent of the issuer’s efforts to remedy its past violations and ensure future 

compliance, and the credibility of its assurances, if any, against further 

violations.” Gateway Int’l Holdings, Inc., Exchange Act Release No. 53907, 

2006 SEC LEXIS 1288, at *19-20 (May 31, 2006).

Respondent’s failure to file required periodic reports is serious because 

the failure constitutes violations of a central provision of the Exchange Act. 

The purpose of periodic reporting is “to supply investors with current and 

accurate financial information about an issuer so that they may make sound 

[investment] decisions.” Gateway Int’l Holdings, Inc., 2006 SEC LEXIS 1288, 

at *26. The reporting requirements are the primary tool that Congress 

“fashioned for the protection of investors from negligent, careless, and 

deliberate misrepresentations” in the sale of securities. Eagletech Commc’ns, 

Inc., Exchange Act Release No. 54095, 2006 SEC LEXIS 1534, at *12 (July 5, 

2006) (quoting SEC v. Beisinger Indus. Corp., 552 F.2d 15, 18 (1st Cir. 1977)). 

Respondent’s violations are also recurrent in that it has failed to file periodic 
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reports for more than four years. See Nature’s Sunshine Prods., Inc., 

Exchange Act Release No. 59268, 2009 SEC LEXIS 81, at *20 (Jan. 21, 2009) 

(failing to file seven required periodic reports due over a two-year period is 

recurrent); Impax Labs., Inc., Exchange Act Release No. 57864, 2008 SEC 

LEXIS 1197, at *25-26 (May 23, 2008) (respondent’s failure to make eight 

filings over an eighteen-month period considered recurrent). Respondent is

culpable because it knew or should have known about the reporting 

requirements. It further failed to heed the delinquency letter sent to it by the 

Division of Corporation Finance. Even if Respondent did not receive such 

letter due to its failure to maintain a valid address on file with the 

Commission as required by Commission rules, the other factors weigh in 

favor of revocation, and scienter is not necessary to establish grounds for 

revocation. See China-Biotics, Inc., Exchange Act Release No. 70800, 2013 

SEC LEXIS 3451, at *37 & n.60 (Nov. 4, 2013). In any event, there is no 

indication that its violations were inadvertent or accidental. Id. Finally, 

Respondent has not answered the OIP, submitted a proposal for the further 

conduct of this proceeding, responded to the show cause order, or otherwise 

participated in the proceeding to address whether it has made any efforts to 

remedy its past violations, and has made no assurances against further 

violations.

Considering these delinquencies, it is necessary and appropriate for the 

protection of investors to revoke the registration of each class of Respondent’s

registered securities.

ORDER

It is ORDERED that, pursuant to Section 12(j) of the Securities 

Exchange Act of 1934, the registrations of each class of registered securities 

of Respondent CNK Global, Inc. (a/k/a American Life Holding Co., Inc.) are 

hereby REVOKED.1

This initial decision shall become effective in accordance with and 

subject to the provisions of Rule 360, 17 C.F.R. § 201.360. Pursuant to that 

rule, a party may file a petition for review of this initial decision within 

twenty-one days after service of the initial decision. A party may also file a 

motion to correct a manifest error of fact within ten days of the initial 

decision, pursuant to Rule 111, 17 C.F.R. § 201.111(h). If a motion to correct 

 

1 This order applies to all classes of Respondent’s securities registered 

under Section 12 of the Exchange Act, whether or not such securities are 

specifically identified by ticker symbol or otherwise in this initial decision.
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a manifest error of fact is filed by a party, then a party shall have twenty-one 

days to file a petition for review from the date of the undersigned’s order 

resolving such motion to correct a manifest error of fact.

Also pursuant to Rule 360, this initial decision will not become final until 

the Commission enters an order of finality. 17 C.F.R. § 201.360(d). The 

Commission will enter an order of finality unless a party files a petition for 

review or a motion to correct a manifest error of fact or the Commission 

determines on its own initiative to review the initial decision as to a party. 

Id. If any of these events occur, the initial decision shall not become final as 

to that party. Id.

A respondent may move to set aside a default. Rule 155(b) permits the 

Commission, at any time, to set aside a default for good cause, to prevent 

injustice and on such conditions as may be appropriate. 17 C.F.R. 

§ 201.155(b). A motion to set aside a default shall be made within a 

reasonable time, state the reasons for the failure to appear or defend, and 

specify the nature of the proposed defense in the proceeding. Id.

_______________________________

Cameron Elliot

Administrative Law Judge