Yantai Dahua Holdings Company Limited
East of Muping, Yantai, Shandong, People’s Republic of China
October 1, 2007
Mr. Daniel L. Gordon
Branch Chief
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC20549
Re:
Yantai Dahua Holdings Company Limited
Amendment No. 3 to Form 20-F for the period ended December 31, 2006
Filed September 18, 2007
File No. 0-50184
Dear Mr. Gordon,
This letter is to respond to Mr. William Demerest’s telephone conversation with our attorney Ms Cletha Walstrand on September 25, 2007, relating to our Company’s Amendment No. 3 to Form 20-F for the period ended December 31, 2006 filed on September 18, 2007.
As requested by the Staff, the financial statements have been revised to include the correct footnotes. Also, an updated report from the independent registered accounting firm is included. Accordingly, we have enclosed herewith the Amendment No. 4 to Form 20-F.
The Company acknowledges that:
1.
The Company is responsible for the adequacy and accuracy of the disclosure in the filing;
2.
Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
3.
The Company may not asset 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 further questions or comments, please do not hesitate to contact me or our attorney Ms Cletha Walstrand at 1322 W. Pachua Circle, Invins, UT 84728; telephone: (435) 688-7317; fax: (435) 688-7318.
Sincerely,
/s/ TANG Yuniang
TANG Yuxiang
Chief Executive Officer
