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