[Letterhead of China Biopharmaceuticals Holdings, Inc.]




Suite 1601, Building A
Jinshan Tower,  No. 8 Shan Xi Road
Nanjing, Jiangsu, China
Fax: 86-25-83205759

                                                                    May 11, 2006
Mr. John L. Krug
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

         Re:      China Biopharmaceuticals Holdings, Inc. (the "Company")
                  Registration Statement on Form SB-2 File No. 333-132693

Ladies and Gentlemen:

         On behalf of the  Company,  request is hereby  made that the  effective
date of the above-captioned Registration Statement be accelerated as soon as may
be practicable.

         In connection with our submission of this request, we acknowledge that:

               o    should  the   Securities   and  Exchange   Commission   (the
                    "Commission")  or the staff,  acting  pursuant to  delegated
                    authority,   declare  the  filing  effective,  it  does  not
                    foreclose the Commission from taking any action with respect
                    to the filing;

               o    the action of the Commission or the staff,  acting  pursuant
                    to delegated  authority,  in declaring the filing effective,
                    does not relieve the  Company  from its full  responsibility
                    for the  adequacy  and  accuracy  of the  disclosure  in the
                    filing; and

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

                                         Very truly yours,

                                         China Biopharmaceuticals Holdings, Inc.


                                         By: /s/ Chris Peng Mao
                                           -------------------------------------
                                           Name: Chris Peng Mao
                                           Title: Chief Executive Officer