January 24, 2005
Via U.S. Mail and Facsimile


Dr. Anchana Chayawatana
Lam Liang Corp.
#2202 The Lakes,
123 Rachidapisek Road
Bangkok 10110 Thailand

RE: 		Lam Liang Corp.
		Registration Statement on Form SB-2
		File No.: 333-121127
		Amended: January 18, 2004

Dear Dr. Chayawatana:

      We have reviewed your amended filing and have the following
comments.  Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.  Please note that the referenced page
numbers refer to the "marked" copy of the prospectus.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General
1. We note your supplemental response that Lam Liang Corporation
has
never intended and does not intend to be a blank check company.
Please disclose this in the prospectus.

2. We note your supplemental response to comment 2 of our January
6,
2005 letter.  Please disclose this within the prospectus.

Risk Factors, page 6

3. In risk factor 12, it appears that you intended to say
"[u]nless
we are successful . . ."  Please revise to clarify the meaning of
this sentence.

Directors, Executive Officers, Promoters and Control Persons, page
16

4. We note your supplemental response to comment 36 of our January
6,
2005 letter.  Please disclose in the prospectus that Alan
Teegardin
is one of your promoters, provide a brief description of his
involvement with other public companies, and how your officers and
directors became acquainted with him.  Please refer to the
definition
of "promoter" in Rule 405 of Regulation C of the Securities Act.

Management`s Discussion and Analysis or Plan of Operation, page 28

5. Please disclose the planned compensation for your General
Manager.

6. We note that, in response to our earlier comment, your plan of
operation includes costs associated with various milestones that
you
will incur prior to generating revenues.  Since you will not have
the
proceeds of this offering available, if at all, until at least 180
days after the offering commences, explain where you will obtain
the
funds necessary to conduct these activities prior to the time the
offering closes.  For example, you disclose that you intend to
spend
$2,000 for the cost of booth at a trade show, and $3,500 on a
local
advertising campaign.  We note that the cash you have on hand will
be
used to cover the expenses of this offering.

Recent Sales of Unregistered Securities

7. Please state what exemption from registration was relied upon
for
the sale of 1,000,000 shares of common stock by Mr. Teegardin to
Dr.
Chayawatana.

Legality Opinion

8. We note the statement in paragraph 5 of the legality opinion
that
"the shares being offered for sale and issuable by the Company
pursuant to this Registration Statement will be validly issued,
fully
paid and nonassessable."  Please revise to state that the shares
will
be duly authorized, fully paid, and non-assessable "when issued as
contemplated by the registration statement," or words to similar
effect.

Subscription Agreement

9. We note that in paragraph (a) of the subscription agreement you
ask investors to represent that they have read the prospectus.
Because this representation may suggest to the subscriber that he
is
foregoing his rights under the federal securities laws unless he
has
read the prospectus, please remove this clause.

Consent of Independent Auditor

10. Please amend your filing to include an updated consent.
Please
note the consent filed as exhibit 23.1 is dated January 10, 2004

Closing Comments

   As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

   We direct your attention to Rules 460 and 461 regarding
requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

   You may contact Tracey McKoy at (202) 824-5486or Alfred Pavot
at
(202) 942-1764 if you have questions regarding comments on the
financial statements and related matters.  Please contact Craig
Slivka at (202) 942-7470 with any other questions.

Sincerely,


      Pamela Long
      Assistant Director



cc:	Michael M. Kessler, Esq.
	(916) 239-4008



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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE