December 7, 2005


By facsimile to (212) 608-9169 and U.S. Mail


Mr. Wilson Cheng
Chairman, Chief Executive Officer, President, and Treasurer
Bestway Coach Express Inc.
2 Mott Street, 7th Floor
New York, NY 10013

Re:	Bestway Coach Express Inc.
	Registration Statement on Form 10-SB
	Filed July 15, 2005
	File Nos. 0-51437

Dear Mr. Wilson:

	We are writing to remind you that we have not received a
response to our August 8, 2005 comment letter on the registration
statement on Form 10-SB of Bestway Coach Express Inc. or Bestway
Coach.  Please advise us within 15 days from the date of this
letter
when we may expect the response.

	We are writing also to remind you that the registration
statement became effective by lapse of time 60 days after the date
on
which it was filed and to address Bestway Coach`s reporting
responsibilities.  For ease of discussion, we will refer to the
date
on which the registration statement became effective as the
"Effective Date."

	Bestway Coach became subject to the reporting requirements of
section 13(a) of the Securities Exchange Act of 1934 on the
Effective
Date.  These reporting requirements obligate Bestway Coach to file
reports on Form 10-KSB for all annual fiscal periods ending after
the
Effective Date and on Form 10-QSB for all quarterly fiscal periods
ending after the Effective Date.  Additionally, Bestway Coach is
obligated to file current reports on Form 8-K when required by
that
form.

	It appears that Bestway Coach is not in compliance with its
reporting requirements under section 13(a) of the Securities
Exchange
Act of 1934.  If Bestway Coach is in compliance with its reporting
requirements, please contact us within 15 days from the date of
this
letter so that we can discuss why our records do not indicate that
compliance.  Alternatively, if Bestway Coach is not in compliance
with its reporting requirements, Bestway Coach should file all
required reports within 15 days from the date of this letter.

	If Bestway Coach is eligible to terminate its registration,
Bestway Coach may do so by filing a Form 15 with the Commission.
While the filing of a Form 15 may cease Bestway Coach`s ongoing
requirement to file periodic and current reports, it would not
remove
Bestway Coach`s responsibility to file all reports required under
section 13(a) of the Securities Exchange Act of 1934 that were due
on
or before the date on which Bestway Coach filed a Form 15.

      You may direct questions on accounting comments to Ryan E.
Rohn, Staff Accountant, at (202) 551-3739 and Nathan N. Cheney,
Assistant Chief Accountant, at (202) 551-3760.  You may direct
questions on this letter, other comments, and disclosure issues to
Edward M. Kelly, Senior Counsel, at (202) 551-3728 or Christopher
B.
Edwards, Special Counsel, at (202) 551-3742.

Very truly yours,





Pamela A. Long
					    Assistant Director



Mr. Wilson Cheng
December 7, 2005
Page 1








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

         DIVISION OF
CORPORATION FINANCE