[Letterhead of Baker & McKenzie]
VIA EDGAR

April 5, 2006

Mr. Carlton Tartar
Assistant Chief Accountant
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

RE:      China Biopharmaceutical Holdings, Inc. - Item 4.01 Form 8-K

Dear Mr. Tartar:

On behalf of China  Biopharmaceutical  Holdings,  Inc. (the  "Company"),  we are
hereby filing the Amendment (the "Amendment") to the Company's current report on
Form 8-K filed on December 29, 2005 (the "Form  8-K").  The  Amendment  reflects
changes  in  response  to the  letter of  comments,  dated  March 30,  2006 (the
"Comment Letter"), issued by the Staff of the Commission.  Three courtesy copies
of the Amendment,  marked to show changes from the Form 8-K as previously filed,
are being furnished to you under separate cover to expedite your review.

The purpose of this letter is to clarify the Company's response to various
matters raised in the Comment Letter, as reflected in the Amendment. Unless
otherwise indicated, terms used herein without definition have the same meanings
as are ascribed to them in the Form 8-K.

The numbered  responses in this letter are keyed to the  corresponding  items in
the Comment Letter.

1.       We note the first paragraph of your disclosure.  Item  304(a)(1)(ii) of
         Regulation S-K requires you to disclose whether the former accountant's
         report on the  financial  statements  for  either of the past two years
         contained an adverse opinion, a disclaimer of opinion, or was qualified
         or modified as to  uncertainty,  audit scope or accounting  principles;
         and to describe the nature of each such adverse opinion,  disclaimer of
         opinion,  modification or qualification.  This would include disclosure
         of uncertainty  regarding the ability to continue as a going concern in
         the accountant's report. Please revise your disclosure accordingly.

         The Company has amended its Form 8-K to include the disclosure that the
audit  report of the former  accountants,  Kempisty & Company  Certified  Public
Accountants, P.C. ("Kempisty"), did not contain an adverse opinion or disclaimer
of opinion,  or was  qualified or modified as to  uncertainty,  audit scope,  or
accounting principles.





2.       Please obtain and file an Exhibit 16 letter from the former accountants
         stating whether the former accountant agrees with your revised Item 304
         disclosures, or the extent to which the accountant does not agree.

         The Company has filed as Exhibit 16.1 to the  Amendment  from  Kempisty
stating that Kempisty agrees with the revised Item 304 disclosures.






                                                               Very truly yours,

                                                                /s/ Howard Jiang
                                                               Howard Jiang

cc: China Biopharmaceutical Holdings, Inc.
    --------------------------------------
    Peng Mao
    Floyd Huang