CHINA HIGHLANDS LIMITED
4519 Admiralty Way, Suite A
Marina del Rey, California 90292
January 24, 2011
Russell Mancuso
Branch Chief
Securities & Exchange Commission
450 Fifth Street
Washington, DC 20549
Re:
China Highlands Limited
Registration Statement on Form 10-12G
File No. 000-54098
Dear Mr. Mancuso:
In connection with your review of the above captioned Form 10-12G. I acknowledge 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 assert comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely yours,
/s/ Jeremy Mork
Jeremy Mork
President and Chief Financial Officer