DALIAN CAPITAL GROUP, INC. Suite 900, 850 West Hastings Street. Vancouver, BC V6C 1E1 Tel : 604-801-5022 Fax : 604-876-5564 January 5, 2010 United States Securities and Exchange Commission Washington, D.C 20549 Attention : Brian Bhandari or Raj Rajan or Tia Jenkins. File No. 000-52185 Dear M/s Tia Jenkins, Re : Form 10-K for Fiscal Year Ended December 31, 2008 Item 9A Controls and Procedures (will be amended as follows) As supervised by our board of directors and our principal executive and principal financial officers, management has established a system of disclosure controls and procedures and has evaluated the effectiveness of that system. The system and its evaluation are reported on in the below Management's Annual Report on Internal Control over Financial Reporting. Our principal executive and financial officer has concluded that our disclosure controls and procedures (as defined in the 1934 Securities Exchange Act Rule 13a-15(e)) as of December 31, 2008, are not effective, based on the evaluation of these controls and procedures required by paragraph (b) of Rule 13a-15. There is a material weakness in the registrant's internal control over financial reporting as error was reported that 2,000 shares of common stock at $0.15 per shares were issued on November 21, 2008, when actually none were issued. The management has made changes in internal control over financial reporting that reconciliation of shares with the Transfer Agent's list to be carried out at every period or year end. Management's Annual Report on Internal Control over Financial Reporting Management is responsible for establishing and maintaining adequate internal control over financial reporting, as such term is defined in Rule 13a-15(f) of the Securities Exchange Act of 1934 (the "Exchange Act"). Internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with U.S. generally accepted accounting principles. Management has re-assessed the effectiveness of internal control over financial reporting as of December 31, 2008. We carried out this re-assessment using the criteria of the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control-Integrated Framework. This annual report does not include an attestation report of our registered public accounting firm regarding internal control over financial reporting. Management's report was not subject to attestation by our registered public accounting firm, pursuant to temporary rules of the Securities and Exchange Commission that permit us to provide only management's report in this annual report. Management concluded in this assessment that as of December 31, 2008, our internal control over financial reporting is effective. There have been changes in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d- 15(f) under the Exchange Act) during the fourth quarter of our 2008 fiscal year that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting. Re : Form 10-Q for the Quarter Ended June 30, 2009 and Form 10-Q for the Quarter Ended September 30, 2009. Item 4T. Controls and Procedures (will be amended as follows) The Company's Chief Executive Officer and its Chief Financial Officer are primarily responsible for the accuracy of the financial information that is presented in this Quarterly Report. These officers have as of the close of the period covered by this Quarterly Report, evaluated the Company's disclosure controls and procedures (as defined in Rules 13a-4c and 15d-14c) promulgated under the Securities Exchange Act of 1934 and determined that such controls and procedure were not effective in ensuring that material information relating to the Company was made known to them during the period covered by this Quarterly Report. There have been changes in our internal control over financial reporting (as defined in Rules 13a-15(f) and 15d- 15(f) under the Exchange Act) during the fourth quarter of our 2008 fiscal year that have materially affected, or reasonably likely to materially affect, our internal control over financial reporting. Please advise us whether the above amendments are agreeable to you and appreciate your comments. We will file amend to include in plain text and will file a Form 10-K/A and a Form 10-Q/A for the periods ended June 30, 2009 and September 30, 3009 within 10 days after receiving a reply to our letter. Thanking you in advance. Yours truly, /s/ Michael Lee Michael Lee Chief Accounting Officer