SNELL WYLIE & TIBBALS
                           A PROFESSIONAL CORPORATION
                             Attorneys & Counselors

8150 North Central Expressway                           Telephone:  214.691.2500
Suite 1800                                              Facsimile:  214.691.2501
Dallas, Texas 75206



                                February 8, 2006



Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549

          Re:  Orsus Xelent Technologies, Inc.
               Commission File No. 333-117718

Ladies and Gentlemen:

         As legal counsel to Orsus Xelent Technologies, Inc. (the "Company"), we
are providing  this letter on behalf of the Company.  The purpose of this letter
is to respond to the  comment  of the staff in its letter to the  Company  dated
December  23,  2005,  relating  to the Form 10-Q  filed by the  Company  for the
quarterly period ended June 30, 2005, and the Form 10-Q filed by the Company for
the quarterly period ended September 30, 2005.

         In response to the staff's  comment,  the Company has amended  both its
Form 10-Q for the  quarterly  period ended June 30, 2005,  and its Form 10-Q for
the  quarterly  period  ended  September  30, 2005,  to include the  information
required by Item 307 of Regulation S-K, as well as the  information  required by
Item 305 of  Regulation  S-K. The Forms 10-Q/A for the  respective  periods have
been filed in EDGAR format with the SEC on the date first set forth above.

         Please note that in order to avoid investor  confusion as to the reason
for these  filings,  the Company has chosen,  as it  understands is customary in
amendments  to these Forms,  to provide in each amended Form 10-Q/A only the new
information  required in order to make that Form complete and  accurate,  rather
than a restatement of the entire Form with that information included.

         The Company acknowledges that:

         o        the Company is  responsible  for the  adequacy and accuracy of
                  the disclosures in its filings;

         o        staff  comments or changes to  disclosure in response to staff
                  comments  do not  foreclose  the  Commission  form  taking any
                  action with respect to the filing; and






Securities and Exchange Commission
February 8, 2006
Page 2




         o        the Company may not assert staff  comments as a defense in any
                  proceeding initiated by the Commission or any person under the
                  federal securities laws of the United States.

         As  mentioned  in the  staff's  letter,  the  Company is aware that the
Division of Enforcement has access to all  information  the Company  provides to
the staff of the Division of Corporation  Finance in its review of the Company's
filings or in response to its comments on the Company's filings.

         Please contact the  undersigned if you have any additional  comments or
questions with respect to the filing of the Company.

                                                            Very truly yours,



                                                            /s/ Phillip A. Wylie

cc:      Mr. Wang Xin
         Orsus Xelent Technologies, Inc.