August 10, 2007

Mr. Richard Tan
Chief Executive Officer
Stone Tan China Acquisition Corp.
9191 Towne Center Drive, Suite 410
San Diego, California 92122


      Re:	Stone Tan China Acquisition Corp.
      	Amendment No. 4 to Registration Statement on Form S-1
   Filed August 6, 2007
   File No. 333-142729


Dear Mr. Tan:

      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.

General
1. Please revise the cover page to identify the nine states and
disclose that investors may only purchase shares if they reside in
one of the nine states or are institutional investors.
2. We note your response to prior comment three and the revised
disclosure on page 21.  It is unclear why you qualify the
disclosure
by stating that the executive officer and directors "may" have
conflicts that must be presented to other entities "[i]f
appropriate."  Please revise to state, if true, that the executive
officer and directors must present opportunities first to Kap
Stone
Paper, McDonald`s and the other entities, identifying each entity.
3. We note your response to prior comment four.  Please revise the
heading to the last risk factor on page 34 to reflect the
statement
that investors "will not" be able to acquire or resell your
securities if they reside in the identified states.
4. We note your response to prior comment five.  Please revise the
first risk factor heading on page 34 to state, if true, that
retail
investors in the IPO and aftermarket will only be permitted to
purchase or sell your securities if they reside in the nine
states,
identifying the states.
5. We note your response to prior comment nine.  You state on page
73
that Messrs. Stone and Tan "have a fiduciary obligation to these
companies that take priority over us."  You also state that to
minimize conflicts of interest they have "agreed to present to
[you]
for [your] consideration any company or business" meeting certain
requirements.  Please revise to reconcile the inconsistency.  Does
the phrase "subject to their respective fiduciary obligations"
mean
that they will present opportunities appropriate for Kap Stone
Paper,
McDonald`s, Pacific Millennium, Samling and Domtar to those
entities
before presenting them to you?  If so, it is unclear what effect
the
agreement to present any conflicting business opportunities to you
first would have.  Please revise accordingly.

* * * * *

      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.

      You may contact Angela Halac at (202) 551-3398 if you have
questions regarding the financial statements and related matters.
Please contact James Lopez at (202) 551-3536 with any other
questions.

      					Sincerely,



      					John Reynolds
      					Assistant Director

cc:	Fran Stoller, Esq.
	Fax (212) 214-0706