Nevaeh Enterprises Ltd.
25 Jin Hua Street
Chang Chun, Ji Lin
China, 130000
Phone: (136) 6430-8646
November 1, 2007
Mark P. Shuman, Branch Chief-Legal
Securities and Exchange Commission
100 F. Street North East
Washington, DC
USA 20549
Re: Nevaeh Enterprises Ltd.
Registration Statement on Form SB-2 Amendment No. 1
Filed August 7, 2007
File No. 333-144681
Dear Mr. Shuman:
We have reviewed your comment letter and have taken every effort to respond accurately and fully to meet your satisfaction. Provided below is our point by point response to your comments. If you should have any further questions, please feel free to contact Nevaeh Enterprises Ltd. via facsimile at 011-8620-3885-1164.
Comment
1. As per communication with Ms. Janet Trost, Ms. Trost has indicated her firm does not wish to continue as the Company's U.S. agent for service. Ms. Trost has advised that she does not wish to receive mail on behalf of the Company and have the mail forwarded on again.
As such, it would be inappropriate for the Company to revise the front cover page of its Form SB-2 filing to indicate Ms. Trost's firm as the Company's US. agent for service.
As of the date of this letter, the Company does not engage any firm or individual as the Company's U.S. agent for service.
The Company has installed a corporate fax line to facilitate the receiving of written communication from outside parties via facsimile. The Company's dedicated fax line is 011-8620-3885-1164.
2. Please find the Undertaking section revised to include the entire item required by Item 512(g)(2) of Regulation S-B.
3. Please find a revision made under the section, "Description of Securities", to indicate that the Company has not engaged the services of a transfer agent. This was previously incorrectly filed by the Company's EDGAR agent.
To clarify, Ms. Janet Trost is a simply a law firm and does not provide transfer agent services in any way.
Sincerely,
Qi Tang
President