November 3, 2005 VIA MAIL AND FACSIMILE Mr. Peter Chang, Chief Financial Officer DSG International Limited 17/F Watson Centre 16-22 Kung Yip Street Kwai Chung, N T Hong Kong 	Re:	DSG International Limited 		Form 20-F/A for Fiscal Year Ended December 31, 2004 Filed October 25, 2005 		File No. 0- 19804 Dear Mr. Chang: We have considered your amendment filed October 25, 2005 in response to our comments and have the following additional comments. Where indicated, we think you should revise your document in future filings in response to these comments. If you disagree, we will consider your explanation as to why our comment is inapplicable or a future revision is unnecessary. Please be as detailed as necessary in your explanation. Form 20-F/A for the Fiscal Year Ended December 31, 2004 Item 15 - Controls and Procedures 1. Please incorporate the following additional changes into your disclosure: a)	To the extent that you chose to include the definition of disclosure controls and procedures in your discussion of your assessment required by Item 15(a) of Form 20-F, please include the entire definition. In this regard, you have omitted the second sentence of the definition as set forth at Exchange Act Rules 13a-15(e) and 15d-15(e). b)	If you are not reporting on your system of internal controls over financial reporting, please exclude the elements of that definition from your definition of disclosure controls and procedures. See Exchange Act Rules 13a-15(f) and 15d-15(f). Exhibits 12.1 and 12.2 2. Do not include the principal officer`s title in the opening line of the certification. Rather it should be relocated under his signature. Closing Comments As appropriate, please comply with these comments in future filings. You may contact Gabrielle Malits, Staff Accountant, at (202) 551- 3702 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551-3683 with any other questions. 								Sincerely, 								Jill Davis 								Branch Chief cc:	Robert Sullivan 	Pillsbury Winthrop Shaw Pittman 	Facsimile 415-983-1200 ?? ?? ?? ?? Mr. Patrick Chang DSG International Limited November 3, 2005 page 1