HART & TRINEN, LLP
ATTORNEYS AT LAW
1624 Washington Street
Denver, CO 80203
William T. Hart, P.C. ________ Email: harttrinen@aol.com
Donald T. Trinen Facsimile: (303) 839-5414
(303) 839-0061
November 29, 2006
Scott Anderegg
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Re: Tian'an Pharmaceutical Co., Ltd.
Registration Statement on Form SB-2
File No. 333-135434
This office represents Tian'an Pharmaceutical Co., Ltd. (the "Company").
Amendment No. 5 to the Company's registration statement has been filed with the
Commission. This letter contains the Company's responses to the comments
received from the Staff by letter dated November 28, 2006. The paragraph numbers
in this letter correspond with the numbered paragraphs in the Staff's comment
letter.
Page Number
-----------
C-1 Comment complied with. Note 10 has been revised to Note 10,
reflect the reclassification between general and 12-31-05
administrative expenses and the provision for and 9-30-06
income taxes. financials
C-2 Comment complied with. Statement of
Operations for
three months
ended 9-30-06
If you should have any questions concerning the foregoing, please do not
hesitate to contact the undersigned.
Very Truly Yours,
HART & TRINEN, L.L.P.
/s/ William T. Hart
William T. Hart
WTH:ap