UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
      October 11, 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. 7 to Registration Statement on Form S-1
   Filed October 5, 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.


Summary
1. Please refer to comment one from our letters dated June 8, 2007
and July 6, 2007.  Revise to briefly describe the factors that
were
considered in decreasing the size of the offering from $300
million
to $200 million.  Please address any changes to the size or nature
of
potential target companies as a result of the decrease.
2. We note disclosure of the co-investment on pages four, seven,
and
elsewhere, and the statement on page 10 regarding the co-
investment`s
"price equal to the initial per share amount in the trust
account."
Please revise to quantify the estimated price on page four and in
the
carryover paragraphs on pages 80-81.  Your revised disclosure on
pages 80-81 should clarify the terms of purchases from the
company,
including the price and whether or not and how the consideration
could be used in connection with a business combination.
3. In this regard, please revise to clarify under what
circumstances,
if any, Messrs. Stone and Tan would not be required to purchase
securities valued at $10 million.  Would the securities purchase
or
any other agreement prevent them from purchasing securities of
Stone
Tan in the open market in addition to the $10 million covered by
the
agreement?  Also, please clarify who the "Purchasers" are as
identified in the securities purchase agreement.

General
4. Please refer to your response to comment two from our letter
dated
July 6, 2007.  Please advise us of any clearances from the states
identified on the cover page.
5. We remind you to please provide us with a copy of the letter or
a
call from the NASD that the NASD has finished its review and has
no
additional concerns regarding the underwriting arrangements in
this
offering.
6. With the request for acceleration, please provide the company`s
representations identified at the end of our letter dated June 8,
2007.



* * * * *

      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

Richard Tan
Stone Tan China Acquisition Corp.
October 11, 2007
Page 1