Mail Stop 7010

      March 8, 2006

Mr. Xue Lian Bian
Linkwell Corporation
c/o James M. Schneider, Esq.
Schneider Weinberger & Beilly LLP
2200 Corporate Blvd, NW, Suite 210
Boca Raton, FL 33431

Re:	Linkwell Corporation
	Registration Statement on Form SB-2
	Filed on February 8, 2006
	File No. 333-131666

Dear Mr. Bian:

      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
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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General

1. Please comply with the following comments in your current
registration statement and, to the extent applicable, in future
exchange act filings.

2. Please provide updated financial statements and related
disclosures, as necessary, to comply with Item 310(g) of
Regulation
S-B.

3. Throughout this document and in recent press releases, you
indicate that your disinfectants have been proven to prevent the
spread of airborne viruses such as bird flu virus and SARS. You
also
assert that some of your products are specifically targeted to
treat
avian flu. Disclose the basis for these assertions and describe
how
your products differ from other competitors` disinfectants in this
regard. If you funded or were otherwise affiliated with any of the
studies or reports, please disclose this.  Note that if any of
this
information was prepared by a third party for inclusion in this
registration statement, you should file the consent of such party
as
an exhibit.  If you do not have appropriate independent support
for
these statements, please revise this language. We may have
additional
comments after we review your response.

4. In recent press releases, you describe that you acquired an
import/export division from Xinjida Trading PTE Limited. Please
describe this acquisition and the new business in the prospectus.
Mr.
Bian has been quoted in press releases as follows: "We will be
able
to consolidate our international trading businesses with a goal of
improving profit margins and increasing distribution channels. . .
..
Our goal is to achieve up to $30 million in annual sales for 2006.
We
believe completion of this acquisition will also allow Linkwell to
achieve its goal to qualify for listing on a major U.S. Exchange."
Please explain these statements.

5. We note that the report by Market Advisors Research, available
through your website, contains a statement regarding a return of
over
400%, which may be seen as improper hyping of the company`s
securities.  Publication of information made in advance of a
proposed
offering which has the effect of conditioning the market or
arousing
public interest in the issuer may constitute an offer under the
Securities Act of 1933.  It is suggested that consideration be
given
to revising the content of your website so that information is
properly archived as contemplated by Rule 433(e)(2) or to omit all
improper disclosures from your website.

6. Please tell us if you, China Direct Investments or other
affiliates funded or were otherwise affiliated with the reports
issued by Harbinger Research and Market Advisors Research.

7. Please update the information in the prospectus to the most
recent
practicable date.

8. Please do not use smaller type in tables, as you do on pages 3
and
56, for example.

Registration Statement Cover Page

9. Please add the name and address of your agent in the United
States
authorized to receive notice.

10. It does not appear that the anti-dilution provisions of the
convertible preferred stock and the common stock purchase warrants
come within the transactions defined in Rule 416.  Please revise.
Prospectus Summary, page 2

11. Please clarify that you regard Likang`s operations as your
primary business. Disclose that Shanghai Shanhai Group, an
unaffiliated third party, owns the remaining 10% of Likang, and is
owned by Group Employee Share-holding Commission and Baoshan
District
Dachang Town South Village Economic Cooperation Club. Also briefly
describe these entities and they degree of management control, if
any, they have over Likang.

Cautionary Statement Regarding Forward-Looking Information, page 4

12. Please move this section after the Risk Factors. Sections
27A(b)(1)(C) of the Securities Act and Sections 21E(b)(1)(C) of
the
Exchange Act expressly state that the safe harbor for forward-
looking
statements does not apply to statements made by an issuer of penny
stock. Please revise accordingly.

Risk Factors, page 4

13. Please delete the second sentence of the first paragraph. All
material risks should be described in the risk factors section.
If
risks are not deemed material, you should not reference them.

14. Some risk factors include language like "we cannot assure you"
or
"there is no assurance."  Since the risk factors should set forth
the
potential risk and not your inability to assure or guarantee,
please
revise.

15. Please avoid language in risk factors like "adverse affect" or
"negatively affected."  Instead, please state what the specific
impact will be on your financial condition or results of
operations.

16. Please add a prominent risk factor relating to your conflicts
of
interest. Disclose in this risk factor your related party
transactions and the degree of dependence on your affiliates,
Shanghai Likang Pharmaceuticals Technology Company and Shanghai
Likang Meirui Pharmaceutical High-Tech Co, Ltd. We note that these
affiliates provide some of your raw materials and products, sell
your
products and one is also your major customer.

17. Please add a risk factor regarding a default on your Series B
preferred stock. We note that the dividends increase to 20% if an
event of default has occurred.

18. Please add a risk factor if your rate of profit is capped by
government regulations.

We will need to raise additional capital... page 5

19. Your disclosure in this risk factor that you do not have
sufficient working capital appears to contradict disclosure in the
prior risk factor where you indicate that you have a working
capital
surplus.  Please clarify.

Our operations are located in the PRC... page 8

20. Please expand upon the items in the bulleted list on page 9 to
briefly explain these differences.

Securities Authorized for Issuance under Equity Compensation
Plans,
page 13

21. Please describe the material features of the equity
compensation
plans that were not approved by shareholders.

Management`s Discussion and Analysis or Plan of Operation, page 15

22. Please describe your plan of operation for the next twelve
months. See Item 303(a) of Regulation S-B.

23. Please discuss the components of your cost of sales in greater
detail. For example, discuss the cost of raw materials and the
effect
of raw material prices on your cost of sales.

24. Please describe the related party transactions and loans in
greater detail.

Results of Operations for September 30, 2005, page 17

25. Quantify and discuss the impact of, and the facts and
circumstances that lead to, the increases you recorded in the
allowances related to accounts receivable and inventory during the
interim period.

26. We note that your selling expenses increased during the period
and year ended September 30, 2005 and December 31, 2004 due, in
part,
to increased local tax costs.  Please clarify the nature of these
taxes and explain why you classify them as selling expenses.  If
applicable, please quantify any offsetting tax proceeds you
receive
or include in revenues during each period presented.

Liquidity and Capital Resources, page 20

27. Please revise the analysis of your cash flows to explain the
underlying factors behind the changes in your balance sheet
accounts,
rather than just reciting the numbers from the face of your
statements of cash flows.  In this regard, you should explain why
balances significantly increased or decreased, including the
increases in accounts receivable and amounts due from related
parties
at September 30, 2005.  Specifically disclose and discuss trends
in
days outstanding for receivables and inventory.  Please refer to
Section 4.B. of our Release 33-8350.

28. If you do not update your financial statements to December 31,
2005, please add an analysis of your annual cash flows for
December
31, 2004 and 2003, in addition to the current analysis of your
interim cash flows.

29. Please disclose and discuss the cash distributions to
shareholders.  We note that these distributions represent a
material
use of cash and are essential to an understanding of your
liquidity.
You should disclose how the distributions were are determined and
to
whom they were paid.  If the distributions were not paid on a pro
rata basis to each shareholder based on their ownership interest,
you
should explain to us how and why your accounting is appropriate.
You
should also address the fact that the distributions exceeded net
income in 2004 and 2003.  If you have a contractual commitment or
anticipate making distributions in the future, you should disclose
and discuss that fact.

Recent Capital Raising Transactions, page 22

30. Please identify the names of the investors to whom you paid a
due
diligence fee and warrants. Disclose the purpose for this payment.

31. Please describe in greater detail how you intend to use the
$1.5
million for working capital purposes.

Our Business, page 26

New Product Development, page 34

32. Please disclose the status of your publicly announced new
products, the chemical indicating card, chemical indicating
adhesive
tape, and chemical indicating labels based on a new steam pressure
sterilization application. See Item 101(b)(3) of Regulation S-B.

33. Please estimate the amount spent during each of the last two
fiscal years on research and development activities. See Item
101(b)(10) of Regulation S-B.

34. Please explain what you mean by critical acclaim and critical
uses for An`erdian Type 3 Skin and Mucous Membrane Disinfectant.

35. Please describe in greater detail what you mean when you state
that your new disinfectants containing Hypericin are in the
initial
development stage.

36. Please expand on your disclosure that you intend to coordinate
your efforts with the Shanghai Municipal Center for Disease
Control &
Prevention to develop a new disinfectant series to treat avian
flu.
For example, disclose whether you have any agreements with the
Center
relating to this effort.

Intellectual Property, page 35

37. Please disclose when your material intellectual property
rights
will terminate.

Competition, page 36

38. For each bullet point that you list as a competitive strength
that differentiates your company, provide a more detailed
explanation. For example, explain how your advanced technology is
a
competitive strength as compared to your primary competitors.

Executive Compensation, page 44

39. Please provide the 2005 compensation information as required
by
Item 402 of Regulation S-B.

Certain Relationships and Related Transactions, page 49

40. Please clarify the last sentence of the first paragraph.

41. Note 3 on page F-26 states that Likang is engaged in business
activities with an affiliated entity, Shanghai Likang Machinery
and
Medicine Company. Please provide disclosure regarding this company
and these transactions.

42. Please quantify in dollars the aggregate annual amount of
products purchased by Shanghai Likang Pharmaceutical Technology
Company.

43. Please quantify in dollars the aggregate annual amount of
products Linkwell purchases from Shanghai Likang Meirui
Pharmaceutical High-Tech Co.

44. Please identify the name of the shareholder to whom you owed
$15,000. Describe this transaction in greater detail.

45. Please describe the reasons for the distributions Likang made
in
the amount of $559,633.

46. Please describe the securities issued to China Direct
Investments
and CIIC Investment Banking Services Co. and their role in the
share
exchange agreement.

Principal Shareholders, page 50

47. Please provide the addresses for China Direct Investments and
CIIC Investment Banking Services Co.

48. Please include in the table all the shares (including those
individually held) beneficially held by each principal
shareholder.
We would not object if you list the shares held individually in
the
footnotes. Make similar revisions in the Selling Security Holder
table. See Instruction 5 to Item 403 of Regulation S-B.

49. We note that the website for China Direct Investment states
that
Marc Siegel is the Managing Director of China Direct Investments,
Inc. and Chairman of CIIC Investment Banking and Services
(Shanghai)
Company Limited. Therefore, it appears that Mr. Siegel is the
beneficial owner for shares held by both these companies. Please
revise.

Selling Security Holders, page 55

50. Please disclose how each seller acquired the securities.

51. Please identify the number of shares being offered pursuant to
the different capital raising transactions.

52. Please confirm that none of the sellers currently have open
positions in the common stock.  If any of the sellers do have
short
positions, please indicate the size of the short position.
Supplementally confirm that you are aware of Telephone Interp.
A.65
(July 1997) on this matter, which is publicly available on our
website.

Plan of Distribution, page 60

53. We note your reference to "transferees, pledges or other
successors" on page 61.  Please be advised that you may substitute
a
new selling security holder for an original selling security
holder
through a prospectus supplement if:

* the change is not material;
* the number of shares or the dollar amount registered does not
change; and
* the new selling security holder`s shares can be traced to those
covered by the original registration statement.

You must use a post-effective amendment to add selling security
holders to your registration statement if their ownership cannot
be
traced to the shares registered in the original registration
statement.

Linkwell Tech Group, Inc. Financial Statements for the Year Ended
December 31, 2004

Note 1 - Organization and Summary of Significant Accounting
Policies
Advances from Customers

54. We note "advances from customers" on your balance sheet.
Please
provide a brief description of this account.  Also, revise your
annual and interim financial statements to indicate whether the
advances are from third parties or related parties.

The Company, page F-7

55. Please confirm, and revise the disclosures in your annual and
interim financial statements and throughout the filing to clarify,
if
accurate, that the stock exchange between Linkwell and Likang
essentially resulted in the two former 90% shareholders of Likang
forming a US holding company and did not result in a change in the
underlying ownership interests of Likang.  If this disclosure is
not
accurate, please provide a comprehensive explanation of the stock
exchange, including all ownership interests before and after the
exchange and the basis for your accounting.

Research and Development, page F-9

56. Please quantify research and development expenses for each
period
you present a statement of operations.  Refer to paragraph 13 of
SFAS
2.

Minority Interest, page F-10

57. We note your disclosures related to losses applicable to the
minority interest.  It appears to us that these disclosures are
not
consistent with your financial statements.  Please advise or
revise.

Note 5 - Related Party Transactions, page F-13

58. Please provide all the disclosures required by paragraph 2 of
SFAS 57.  In this regard, you should more fully explain the nature
of
your relationships with the related parties, you should quantify
and
disclose all related party transactions, and you should disclose
the
terms and manner of settlement for each related party balance.

59. Revise the annual and interim statements of operations to
separately present related party revenues and expenses for each
period presented.

60. We note that your significant customer is an affiliate based
on
common ownership.  Please clarify when you recognize revenue on
sales
to your affiliate and disclose and discuss the terms of these
sales.
If you recognize revenue on sales to your affiliate when you ship
products to them, please help us understand how and why this
policy
is appropriate and complies with SAB 104, in light of the common
ownership.  It is not clear to us that it would be appropriate to
recognize revenue on sales to your affiliate until they ship the
products they purchased from you to unrelated third parties.  In
this
regard, we note the significant increase in the amount due from
the
related party during the current period.  If you recognize revenue
on
sales to your affiliate on another basis, please revise your
revenue
recognition policy to clarify.  It also appears to us that you
should
highlight the fact that a significant percentage of your sales are
to
an affiliate in your disclosures under the summary, risk factors,
MD&A and critical accounting policies.  In addition, based on the
disclosures under Business, we note that you make sales to
independent sales representatives and independent distribution
agents.  Please tell us when you recognize revenue on sales to
these
parties, tell us the terms of these sales, and help us understand
how
and why your disclosed revenue recognition policy is appropriate
and
complies with SAB 104.

Note 6 - Income Taxes, page F-13

61. Please provide all the disclosures required by SFAS 109.

Note 9 - Operating Risk
Country Risk - page F-14 and Performance of Subsidiaries Risk -
page
F-15

62. We note the disclosure that your revenues are mainly derived
from
the sale of herbs, beet sugar and veterinary products and that you
hope to expand your operations outside the PRC.  These disclosures
are not consistent with the descriptions of your business
elsewhere
in the filing.  Please advise or revise.  We also note your
reference
to partner companies and their three Chinese subsidiaries.  Please
identify these partner companies and their subsidiaries, or remove
this reference.  Please confirm and revise your disclosures to
clarify that you only have one Chinese subsidiary.  In addition,
please ensure that each footnote disclosure in your financial
statements relates to your company.

Note 10 - Subsequent Events

63. Based on the date of the auditors` report and the dates of
certain transactions and events disclosed in note 10, it is not
clear
to us if all the disclosures in note 10 are covered by the
auditors`
report.  Please clarify or revise as appropriate.

64. We note your disclosure concerning the sale of Aerisys
Incorporated to Kirshner`s former CEO.  Please tell us how you
accounted for this sale.  If you recorded a gain or loss, please
quantify the amount and tell us how it was calculated.

65. We note your discussion of the accounting for your issuance of
6%
Series A Convertible Preferred Stock and the related common stock
purchase warrants.  We have the following comments:

* It is not clear from the disclosures in your September 30, 2005
financial statements if these warrants were recorded on your
balance
sheet at issuance.  Please advise or revise.  Refer to EITF 00-19,
EITF 98-5, and EITF 00-27.
* Please provide us with your analysis of whether these stock
purchase warrants should be classified as a liability or as
equity.
Your analysis should specifically address the criteria in EITF 00-
19.
* It is unclear to us how you calculated the beneficial conversion
feature related to this preferred stock issuance.  Please show us
your calculations, including how you determined the fair value of
the
warrants.
* Please clarify if you used the two class method to calculate EPS
for the period ended September 30, 2005.
* Please clarify if you recorded dividends on the Series A
preferred
stock during the period ended September 30, 2005.

66. We note your discussion of the December 2005 issuance of your
6%
Series B Convertible Preferred Stock and the related common stock
purchase warrants.  We have the following comments:

* Please tell us how you accounted for this equity issuance.
Please
specifically address if and how you recorded these warrants on
your
balance sheet, tell us if and how you recorded any beneficial
conversion feature, including the fair value you allocated to the
warrants, and provide us your calculations.
* Please provide us with your analysis of whether these stock
purchase warrants should be classified as a liability or as
equity.
Your analysis should specifically address the criteria in EITF 00-
19.
* We read that you "paid a due diligence fee of $65,000 in cash
and
Class B Warrants to purchase 866,665 shares of [your] common stock
to
certain of the investors."  Please clarify the meaning of this
sentence, including whether you are referring to the sale of stock
to
your investors or the purchase of your stock back from your
investors.

Linkwell Corporation September 30, 2005 Financial Statements

Consolidated Balance Sheet, page F-18

67. It appears to us that you may have included amounts you
forwarded
to an affiliate to purchase a building in due from related party
and
current assets.  It appears to us that it may be more appropriate
to
reflect this amount as a deposit and exclude it from current
assets.
Please advise or revise.  In addition, in regard to your purchase
of
a building from an affiliate, please tell us how you will account
for
the purchase, how the purchase price was determined and if and how
you determined the fair market value of the building.  Please be
advised that if the purchase price exceeds the fair market value
of
the building, it appears to us that the excess would be akin to
compensation expense.

Consolidated Statements of Cash Flows, page F-20

68. Please help us understand your basis for classifying the
change
in the amount due from the related party in financing activities
based on the nature of the underlying transactions and the
provisions
of SFAS 95.

Note 4 - Stockholders` Equity
Common Stock, page F-26

69. Please help us understand how you recorded and valued all of
the
equity securities you have issued to China Direct.

Common Stock Warrants, page F-27

70. We read that you granted warrants to purchase 731,034 shares
of
your common stock at $0.3045 in connection with your preferred
stock
funding.  Please reconcile this information to your disclosures
elsewhere in the filing, including the tables immediately below
this
statement, which indicate that your June 2005 preferred stock
funding
included warrants to purchase 3,753,450 shares of your common
stock
at $0.10.

Part II

Item 26. Recent Sales of Unregistered Securities

71. For securities sold for cash, disclose the total offering
price.
For securities sold other than for cash, describe the amount of
consideration received by the company.

Item 27. Exhibits and Financial Statement Schedules

72. Please provide updated consents from your independent
accountants
in each amendment to your registration statement.

73. Some of the descriptions of the exhibits do not accurately
describe the parties in the documents, such as Exhibit 2.3. Please
revise.

74. Please re-file the documents which are not signed to reflect
that
they are executed.

      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 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 filing to be certain that the
filing includes all information required under the Securities Act
of
1933 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.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert staff comments and the declaration
of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as 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 Jennifer Thompson at (202) 551-3737 or Anne
McConnell at (202) 551-3709 if you have questions regarding
comments
on the financial statements and related matters. Please contact
Brigitte Lippmann at (202) 551-3713 or in her absence, Chris
Edwards
at (202) 551-3742 or me at (202) 551-3760 with any other
questions.


Sincerely,



Pamela A. Long
Assistant Director



cc:	James M. Schneider, Esq.
	Schneider Weinberger & Beilly LLP
	2200 Corporate Blvd, NW, Suite 210
	Boca Raton, FL 33431
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Mr. Xue Lian Bian
Linkwell Corporation
March 8, 2006
Page 1



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

         DIVISION OF
CORPORATION FINANCE