SCHNEIDER WEINBERGER & BEILLY LLP
                         2200 Corporate Boulevard, N.W.
                                    Suite 210
                            Boca Raton, Florida 33431

                             telephone 561-362-9595
                             telecopier 561-362-9612

                                                                November 2, 2005

                                    'CORRESP'


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

  Attention:      Jeffrey Riedler
                  Dana Hartz
                  Joel Parker
                  Zafar Hasan

         Re:      Sunwin International Neutraceuticals, Inc. (the "Company")
                  Registration Statement on Form SB-2
                  File Number 333-125300


Ladies and Gentlemen:


     In furtherance to the filing of amendment  number 2 to the  above-captioned
registration  statement,  the staff  provided  the Company  with an oral comment
requesting additional disclosure under "Management's  Discussion and Analysis or
Plan of Operation."  This  additional  disclosure has been added and the Company
has filed amendment number 3 to the above-registration  statement.  Prior to the
filing of this  amendment we  furnished  the staff with faxed page proofs of the
proposed response to the oral comment and the staff subsequently  indicated that
the proposed revision was sufficient to respond to its oral comment.

     Under  separate  cover we will deliver three  courtesy  copies of amendment
number 3 to Dana Hartz,  marked to show the changes from the amendment number 2.
In  addition,  we will  contact  the staff  within the next few days with a view
towards   submitting   the   Company's   request   for   effectiveness   of  the
above-captioned registration statement.

                                                   Sincerely,


                                                   /s/ Roxanne K. Beilly


cc:      Ms. Dongdong Lin