Mail Stop 4561

   January 19, 2006

Mr. Kung-Chieh Huang
Chief Financial Officer
Eupa International Corporation
89 N. San Gabriel Boulevard
Pasadena, CA 91107

      Re:	Eupa International Corporation
		Form 10-KSB for the Year Ended December 31, 2004
		Filed March 31, 2005
		File No. 0-26539

Dear Mr. Huang:

      We have reviewed your response letter dated November 28,
2005
and have the following additional comments.  As previously stated,
these comments require amendment to the referenced filings
previously
filed with the Commission.  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 ask
you
to provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

	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
filings.
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.


Form 10-KSB for the year ended December 31, 2004

Note D - Intangible Assets, page F-12
1. Related to prior comment 3, please provide us with sufficient
detail explaining the nature of costs associated with applying for
new patents and trademarks that you have capitalized and tell us
your
basis for capitalizing these costs.  In addition, please explain
how
you have evaluated such intangible assets for impairment in light
of
your recurring cash and operating losses.

Note I - Discontinued Operations, page F-17
2. We note your response to comment 5.  Please tell us why you
accounted for the reversal of an income tax accrual as a change in
accounting estimate as opposed to a correction of an error in a
prior
period.  Reference is made to APB 20.

Note M - Liquidation Distribution, page F-20
3. We note your response to comment 6.  According to your
disclosure
in Note B your wholly-owned subsidiary, Union Channel Limited, is
consolidated and all intercompany accounts are eliminated upon
consolidation.  In light of this, we are unclear why you have an
"Investment in Union" account and why the dissolution of a wholly-
owned subsidiary and related transfer of cash to you the parent
would
have any effect on your financial statements.  Please amend form
10-
KSB and subsequently filed 10-QSBs to revise your statements of
operations, statements of changes in stockholders` equity and
statements of cash flows to remove all reference to this
liquidation
distribution.

Form 10-QSB for the quarterly period ended September 30, 2005

Item 2.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, pages 9 - 14

Overview, pages 9 - 10
4. We note from your disclosure on page 10 of your Form 10-QSB
that
your "mark-up was 5% for research and development services and 2%
for
patent and fiduciary and administration services."  Please explain
what costs are associated with providing these services and tell
us
how those costs have been reflected in the financial statements.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please file your response on EDGAR.  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
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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

      You may contact Matthew Maulbeck, Staff Accountant, at (202)
551-3466 or the undersigned at (202) 551-3403 if you have
questions.



								Sincerely,



      Steven Jacobs
      Accounting Branch Chief

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Mr. Kung-Chieh Huang
Eupa International Corporation
January 19, 2006
Page 1