China Shoe Holdings, Inc.
488 Wai Qingsong Road
Waigang
Jiading District
Shanghai, PR of China 201800
November 4, 2008
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, NW
Washington, DC 20549
| | Re: | China Shoe Holdings, Inc. (the”Company”) |
| | | Form 10-KSB/A for the fiscal year ended December 31, 2008 |
| | | Amendment Number 2 |
| | | File Number 333-139910 |
Ladies and Gentlemen::
In connection with the fiing of the above referenced amendment to its annual report on Form 10-KSB for the year ended December 31, 2007, the Company hereby acknowledges that:
(a) the Company is responsible for the adequacy and accuracy of the disclosures in its filings; (b) staff comments or changes to disclosure in response to comments do not foreclose the Commission from taking any action with respect to the filing; and ( c) the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
China Shoe Holdings, Inc.
By: /s/ Gu Xianzhong
Gu Xianzhong , President and CEO
