Mail Stop 0610							March 14, 2006

Hoi-ho Kui
Chief Executive Officer
Golden Health Holdings, Inc.
Unit 979, 9/F, HITEC
1 Trademark Drive
Kowloon Bay, Hong Kong

Re:	Golden Health Holdings, Inc.
	Revised Preliminary Information Statement on Schedule 14C
      Filed March 9, 2006
	File No. 0-25845

Dear Mr. Kui:

      We have conducted a limited review of your revised filing
solely with respect to your intended use of newly authorized
common
and preferred stock 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Amendment to the articles of incorporation to increase the number
of
authorized shares of common stock, page 5

1. We note your statement that "currently, there are no plans,
arrangements, agreements or understandings in place with respect
to
the issuance of the newly authorized common stock."  This
statement
appears to contradict a previous statement that the increase in
authorized shares will allow you to satisfy your obligations with
respect to the acquisition of Joy Power.  Please revise to state,
if
true, that with the exception of the number of shares necessary to
complete the acquisition of Joy Power (please state the number),
you
have no current plans, arrangements, agreements or understandings
with respect to the issuance of the newly authorized shares of
common
stock.

2. Please expand the discussion on page 7 concerning the proposed
increase in the number of authorized shares of preferred stock to
explain why the board designated only 50,000 shares of series A
convertible preferred stock in connection with the sale of 129,100
of
such shares.  To the extent the convertible preferred is
convertible
into common stock, please discuss the conversion ratio and the
aggregate number of common shares in which the class A preferred
can
be converted.

******

       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.  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 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 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.

		Please contact John L. Krug, Senior Counsel, at (202)
942-
2979, or me at (202) 942-1840 with any questions.


Sincerely,


Jeffrey Riedler
Assistant Director








cc: Lynne Bolduc, Esquire
      Registered Agent Solutions, Inc.