RICHARDSON & PATEL LLP
10900 Wilshire Boulevard
Suite 500
Los Angeles, CA 90024
Telephone (310) 208-1182
Facsimile (310) 208-1154

June 30, 2005

U.S. Securities and Exchange Commission
Mail Stop 0408
450 Fifth Street, N.W.
Washington, D.C., 20549
Attn: Jonathan Gottlieb, Esq.
Mark Webb, Esq.

Re: Bio-Bridge Science, Inc.
Amendment No. 2 to Registration Statement on Form SB-2
Filed June 29, 2005
File No. 333-121786

Dear Messers. Gottlieb and Webb:

We enclose for filing under the Securities Act of 1933, as amended,
Amendment No. 2 to the above-referenced registration statement (the
"Registration Statement") together with exhibits thereto. Amendment No. 2 to the
Registration Statement contains revisions that have been made in response to
comments received from the staff ("Staff") of the Securities and Exchange
Commission in their letter dated June 3, 2005. Set forth below are Bio-Bridge
Science, Inc's (the "Company") responses to the Staff's comments. We have
reproduced the Staff's comments in bold type and have followed each comment with
our response. References in this letter to "we," "our" or "us" mean the Company
or its advisors, as the context may require. Clean and marked copies of
Amendment No. 2 to the Registration Statement are being provided supplementally
with a copy of this letter for the convenience of the Staff.

Summary, page 3

1. Please revise to provide additional summarized information about the
principal obstacles remaining before you may have a commercial product.
Please provide a realistic estimate of the time it may take before you may
have a commercial product.

U.S. Securities and Exchange Commission
June 30, 2005
Page 2

We have added disclosure about the principal obstacles remaining before we
may have a commercial product to the Summary on page 3. We have also
revised our disclosure to provide a realistic estimate of time before our
product may be brought to market.

Government Regulation in China, Japan and the United States, page 25

2. Please provide estimated times for each step in the regulatory process in
each country. Please clarify the estimated time and capital needed to
bring the vaccine to market in each of the three countries.

We have added disclosure to clarify the estimated times for each step in
the regulatory process as well as the estimated time and capital needed to
bring the vaccine to market in China, the U.S. and Japan.

Competition, page 27

3. Please revise your statement that "we believe we have significant
intellectual property protection to prevent other from developing a
competing vaccine" to clarify that you only believe that you can prevent
others from developing a competing vaccine using the same technology as
yours and that others are developing competing vaccines.

In response to the Staff's comment, we have revised our disclosure on page
27 to clarify that we believe that we can prevent others from developing a
competing vaccine.

Management's Discussion and Analysis, page 28

4. Please review your reference to "pre-clinical testing" to clarify that
this involves testing on animals not humans.

We have revised our disclosure to clarify that pre-clinical testing
involves testing on laboratory animals on pages 3, 5, 6, 8, 9, 13, 23, 28
and 29.

5. Please reconcile the going concern opinion of your auditors as well as
your statement on page 28 that you "will need to obtain additional
financing ... to fund our cash needs and continue our operations for the
next 12 months" with your statement on page 29 that "We believe that we
have adequate cash to satisfy our ...on-going operations...for the next 12
months."

We have deleted the referenced disclosure on page 29.

Consolidated Financial Statements

General

U.S. Securities and Exchange Commission
June 30, 2005
Page 3

1. Please refer to our previous comment 51. We could not locate separate
correspondence from your auditors. Please have your independent accounting
firm supplementally tell us the audit procedures used to determine the
existence, and appropriate values of fixed assets, including construction
in process and the land use right. In addition, the accounting firm should
supplementally tell us their expertise in valuing assets held in China.

We respectfully resubmit the independent accounting firm's supplemental
response as Exhibit A to this letter.

Note 1. Organization and Principal Activities - page F-6

2. Please refer to our previous comment 48. We note discussion of the reasons
why the company has a going concern disclosure in the financial
statements. However, no discussion of management's viable plan to overcome
these difficulties could be located. Please revise here and in MD&A to
include this discussion as required by FRR-16.

In response to the Staff's comment, we have added disclosure to this
section as requested on page 7 of the Notes to the financial statements
for the fiscal years ended December 31, 2004 and December 31, 2004.

Note 5. Loss on investment - page F-12

3. Please revise to disclose management's reasons for acquiring Aegir and why
it subsequently decided to sell.

We have added disclosure to disclose our reasons for acquiring Aegir and
then subsequently selling it.

4. Please revise to disclose how recognizing the note receivable from
Nakagawa Corporation at its present value resulted in loss.

We have revised our disclosure to clarify how recognizing the note
receivable from Nakagawa at its present value resulted in loss.

We hope that the information contained in this letter satisfactorily
addresses the comments by the Staff. Questions or comments regarding the
Registration Statement may be directed to the undersigned by telephone at (310)
208-1182, or by facsimile at (310) 208-1154.

Sincerely,

/s/ Dorothy B. Vinski
Dorothy B. Vinski

Enclosures

U.S. Securities and Exchange Commission
June 30, 2005
Page 4

Exhibit A

WEINBERG & COMPANY, P.A.
- ----------------------------
CERTIFIED PUBLIC ACCOUNTANTS

VIA EDGAR AND COURIER

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, NW
Washington DC, 20549
Attn: Jonathon E. Gottlieb, Esq
Mark Webb, Esq

Re: Bio-Bridge Science, Inc.
Registration Statement on Form SB-2
File No. 333-121786

Messrs Gottlieb and Webb:

We enclose for filing our response to the Staff's comment relating to the
above-referenced registration statement. We have reproduced the Staff's comment
in bold type and have followed the comment with our response

49. Considering the significance of fixed assets; including fixed
assets, construction in process and land use right, held by you in
China, please have your independent accounting firm supplementally
tell us the audit procedures used to determine the existence of
these assets, the appropriate values assigned to these assets in the
consolidated balance sheets and of its expertise in valuing assets
held in China.

Weinberg & Company utilized the services of our correspondent firm, KP Cheng &
Co, a firm chartered in Hong Kong and registered with the PCAOB. In response to
your question, the audit procedures included physical observation of the major
fixed assets and construction in progress, and tests of the accounting records
including vouching of selected items to the vendor's invoices and contracts. As
it relates to the land use right, the audit procedures included vouching of the
amount of the payment for such right and observation and verification that the
original land use right certificate issued by the local authority was properly
issued in the name of the Company's subsidiary, Bio Bridge Science Beijing. All
amounts were recorded as assets by the Company were based upon their historical
cost basis.

We hope that the information contained in this letter satisfactorily addresses
the comments by the Staff.

Very truly yours,

/s/ Weinberg & Company
Weinberg & Company

6100 Glades Road o Suite 314 1925 Century Park East o Suite 1120 One Pacific Place, Suite 805
Boca Raton, Florida 33434 Los Angeles, California 90067 88 Queensway, Hong Kong, P.R.C.
Telephone: 561.487.5765 Telephone: 310.601.2200 Telephone: 852-2780-7231
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