October 29, 2019

Yanping Sheng
Chief Executive Officer
Kemiao Garment Holding Group
6910 S. Cimarron Road, Suite 240
Las Vegas, Nevada 89114

       Re: Kemiao Garment Holding Group
           Amendment No. 1 to Form 10-12G
           Filed October 18, 2019
           File No. 000-56086

Dear Mr. Sheng:

       We have reviewed your amended filing and have the following comments. In
some of
our comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments. Unless we note otherwise, our
references to prior
comments are to comments in our September 23, 2019 letter.

Form 10-12G/A filed October 18, 2019

Business, page 2

1.    In response to our prior comment 3, you disclose that the liabilities and
debts from the
      company's prior business operations "have not been addressed and remain
on the books."
      Please revise to quantify the liabilities and debts that remain on the
company's books. We
      note that the last Form 10-Q for the quarter ended September 30, 2011
reflected over $9
      million in total liabilities, while the current balance sheet, as of June
30, 2019, shows total
      liabilities of $10,916.
 Yanping Sheng
FirstName LastNameYanping Sheng
Kemiao Garment Holding Group
Comapany NameKemiao Garment Holding Group
October 29, 2019
Page 2
October 29, 2019 Page 2
FirstName LastName
Security Ownership of Certain Beneficial Owners and Management, page 14

2.       We note your response to our prior comment 14. Since Jinlin Guo is the
control person of
         Guo Jin Tong Investment, please revise to clarify if his 4.3 million
shares include the 3.6
         million shares held by Guo Jin Tong Investment. Also please revise to
disclose in the
         beneficial ownership table that Yufang Zhu is a director of the
company.
Certain Relationships and Related Transactions, and Director Independence, page
16

3.       We note your response to our prior comment 20. Please revise to
disclose the nature and
         amount of compensation received by Bryan Glass in his role as
custodian.
Recent Sales of Unregistered Securities, page 17

4.       We note your response to our prior comment 18. However, it is still
not clear why you
         state that the restricted shares were sold under Rule 144(i) when,
since you are a shell
         company, Rule 144 is not available for the resale of your securities.
Please revise or
         advise.
5.       We note your response to prior comment 19 and your disclosure that
"YuFang Zhu was
         issued 36,000,000 shares in accordance with the Equity Agreement."
Please clarify your
         reference to "the Equity Agreement" and file it as an exhibit.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Charles Eastman, Staff Accountant at (202) 551-3794 or
Inessa
Kessman, Senior Staff Accountant, at (202) 551-3371 if you have questions
regarding comments
on the financial statements and related matters. Please contact Gregory Dundas,
Attorney
Adviser, at (202) 551-3436 or Kathleen Krebs at (202) 551-3350 with any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Manufacturing
cc:      Rhonda Keaveney