Exhibit 16.1


                      [Letterhead of KND& CO. CPA Limited]




March 18, 2004



Securities and Exchange Commission
Washington, DC 20549

Ladies and Gentlemen:

      We have read  statements  that we understand  Minghua Group  International
Holdings  Limited will include  under Item 4 of the Form 8-K report it will file
regarding the recent change of its auditors.  We agree with such statements made
regarding our firm. We have no basis to agree or disagree with other  statements
made under Item 4.

Very truly yours,

/s/ KND & CO. CPA Limited

KND & CO. CPA Limited