Mail Stop 6010								February 28,
2006

Jing Jing Long
President
10925 Schmidt Road
El Monte, California 91733

Re:	Tank Sports, Inc
	File No. 333-129910
	Filed February 9, 2006

 Dear Mr. Long:

      We have reviewed your 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 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 response to prior comment 17 in which we requested
that you file your agreements with contract manufacturers as
exhibits
to the registration statement.  In your response, you indicated
that
these arrangements are governed by purchase orders and not by
contracts.  However, it is clear that the purchase orders are
material to the business.  Accordingly, in the Business section
you
should include a summary of the terms of the purchase orders and
business arrangements relating to manufacturing your products.
2. We note your response to prior comment 27 and your description
of
the Steady Star loan, which matured in April of 2002.  In this
section, you should disclose the current state of the loan as it
appears that it has been extended.  Please describe the maturity
terms in this section.
3. We note that your fiscal year ends in the next few days.  When
you
file your next amendment, you will need to provide executive
compensation information in the table for fiscal 2006.

Financial Statements
Notes to Financial Statements
Note 2.  Summary of Significant Accounting Policies, page 46
4. Please refer to prior comment 32. Please remove the previously
noted contradiction from your revenue recognition accounting
policy
and include the basis for title transfer as described in your
response to comment 34. This disclosure should be consistent with
your proposed new disclosure in critical accounting policies.

      As appropriate, please amend your filing 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 file your cover letter on
EDGAR under the form type label CORRESP. 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      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 Frank Wyman at (202) 551-3660 or Kevin
Woody,
at (202) 551-3629 if you have questions regarding comments on the
financial statements and related matters. Please contact Zafar
Hasan
at (202) 551-3653 or me at (202) 551-3715 with any other
questions.
      Sincerely,




      Jeffrey Riedler
   Assistant Director

   cc:	William O`Neal
   	The O`Neal Law Firm
   	17100 East Shea Boulevard
   	Suite 400-D
   	Fountain Hills, Arizona 85268
   	F: 480-816-9241

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