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                                                                   July 29, 2008

U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549-6010

Attn: Mr. John L. Krug

                  Re:     China Pharma Holdings, Inc.
                          File No.333-141734
                          Registration Statement on Form S-1
                          Filed July 11, 2008

Ladies and Gentlemen:

On  behalf  of  China  Pharma  Holdings,   Inc.,  a  Delaware  corporation  (the
"Company"),  we have been  authorized  by the Company to present  the  following
responses to your letter dated July 15, 2008 (the "Comment Letter"), relating to
the Company's Form S-1 filed on July 11, 2008 (the "Form S-1").

Concurrently  with this  response to the Comment  Letter,  the Company is filing
Amendment No. 1 to the Form S-1 (the "Amendment").

Your comments have been set forth in italics and  paragraphs  have been numbered
to correspond to the numeration of the Comment Letter.

FORM S-1
- --------

Required signature
- ------------------

1.   With respect to the selling security holders that are non-natural  persons,
     please  expand the  discussion  to indicate the natural  person with voting
     and/or  investment  control over the  securities  held by each  non-natural
     person.

     In response to your comment,  the Company has expanded the discussion about
     the selling security holders in this Amendment.

2.   The  Registration  Statement  should  also be  signed  by the  registrant's
     controller or principal  accounting  officer.  Any person who occupies more
     than one of the  specified  positions  required  to sign  the  registration
     statement should indicate each capacity in which the registration statement
     is signed. See instructions 1 and 2 to Signatures to Form S-3.

     In response  to your  comment,  the  Company has made such  revision on the
     signature page of this Amendment.


If you have further requirements or questions, please do not hesitate to contact
the undersigned at (1408) 947-1960 or by facsimile at (0086-10) 58785566.



                               Very truly yours,

                               KING AND WOOD, LLP


                               By: /s/ Charles Law
                                   ---------------
                                   Charles Law