EXHIBIT
                                    -------

                         THOMAS LEGER & CO., L.L.P. Certified Public Accountants


Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549

Re:  Huayang International Holdings, Inc.
Commission File #0-30173

Dear Sir/Madam:

Thomas  Leger  &  Co.,  L.L.P.  ("TLC")  previously  was  engaged  by  Huayang
International  Holdings,  Inc.  (the  "Company")  as  the  Company's  principal
accountants.  Except  as set forth below, we agree with the statements contained
in  Item 4 of the Company's Form 8-K regarding an event occurring on February 5,
2004:

- -    TLC agrees with the Company's statement in paragraph (a) (i) of Item 4 that
     TLC  resigned  on  February  5,  2004.

- -    TLC  disagrees  with  the  Company's statement in paragraph (a) (ii). TLC's
     report  contained  a  going  concern  qualification.

- -    TLC is not in a position to agree or disagree with the Company's statements
     in  paragraph  (a) (iii) of Item 4 regarding recommendation and approval of
     the  Company's Board of Directors regarding change of accountants. However,
     TLC  initiated  the  event.

- -    TLC disagrees with statement (a) (iv) as it applies to interim periods. TLC
     requested  additional information from the Company regarding impairment, if
     any,  during  the  fourth quarter. TCL was/is not in a position to evaluate
     this  issue  as  it  relates  to  interim  periods.

- -    TLC has had no contact from Weinberg & Company, P.A. regarding the Company.

- -    TLC is not in a position to agree or disagree with the Company's statements
     in  paragraph  (b) on Item 4 regarding consultation between the Company and
     Weinberg  &  Company,  P.A.


Very Truly Yours,

/s/  Thomas Leger & Co., L.L.P.
- -------------------------------
Thomas Leger & Co., L.L.P.
Houston, Texas
February 17, 2004



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