SecProbe.io

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

                                 June 22, 2005

VIA EDGAR AND FEDERAL EXPRESS

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington DC, 20549
Attn:    Bob Carroll
         Carlos Pacho

         Re:  China Cable and Communication, Inc.
              Form 10-K for Fiscal Year Ended December 31, 2004
              File No. 002-98997-NY

Messrs. Carroll and Pacho:

      On behalf of China  Cable and  Communication,  Inc.  (the  "Company"),  we
enclose a marked draft of the Company's  proposed  Amendment No. 1 to Form-10KSB
for the fiscal year ended December 31, 2004 (the "Amended Report").  The Amended
Report  contains  revisions  that  have been made in  response  to the  comments
received from the staff  ("Staff") of the Securities and Exchange  Commission in
their letter dated June 10, 2005. Set forth below are the Company's responses to
the Staff's comments.  We have reproduced the Staff's comments and have followed
each comment  with our  response.  A marked copy of the Amended  Report is being
provided  supplementally  with a copy of this letter for the  convenience of the
Staff.

Form 10-KSB for Fiscal Year Ended December 31, 2004

Plan of Operation, page 32

1.    Expand the  disclosure in the liquidity and capital  resources  section to
      discuss the issuance of a going concern opinion by the auditors. Include a
      detailed  discussion  of  management's  viable  plan for  overcoming  your
      financial  difficulties.  Discuss in detail your cash requirements  during
      the next twelve  months and your  ability to generate  sufficient  cash to
      support  operations.  Expand this discussion to  specifically  include the
      manner in which you  intend  to  generate  future  revenues.  Update  this
      disclosure in each  subsequent  Form 10-Q.  Refer to Section 607.02 of the
      Financial Reporting Codification.
<PAGE>

      RESPONSE:

      In response  to the Staff  comment,  the  Company  proposes to include the
      following  added  disclosure in the Amended Report and to subsequent  Form
      10-QSB's:

      The  Company's  registered   independent  public  accountants,   in  their
      independent  accountants' reports on the consolidated financial statements
      as of and  for  the  year  ended  December  31,  2004,  have  included  an
      explanatory   paragraph  in  their  opinion   indicating   that  there  is
      substantial  doubt  about the  Company's  ability to  continue  as a going
      concern because the Company has suffered  recurring losses from operations
      and has a working capital deficit.

      Although  the  Company  incurred  an  operating  loss for the  year  ended
      December 31, 2004, the Company generated positive cash flows of $2,588,912
      from operating activities.  The operating loss for the year ended December
      31, 2004 included items which are of either a non-cash or a  non-recurring
      nature:  (i) expensed common stock and warrants issued for consulting fees
      of   $2,564,354,   (ii)  expensed   common  stock  issued  for  directors'
      compensation of $347,980, and (iii) a provision for bad debt of $3,000,000
      relating to a deposit  paid in November  2003 for the  Company's  proposed
      acquisition of Macau Media and its subsidiaries.

      The cash requirements of the Company and its subsidiaries  during the next
      twelve months  include the normal  operating  expenditures  of the Baoding
      joint venture,  payments for  professional  fees, and  compensation of the
      Company's  directors.  While the Baoding joint venture has been generating
      net income from its operations and does not have any material  commitments
      for capital  expenditures,  we  anticipate,  based on the scale of Baoding
      joint  venture's  existing  operations,  that the Baoding joint  venture's
      projected  cash flows from  operations  would be sufficient to support its
      planned  operations  for the next  twelve  months.  To make  the  required
      payments for professional  fees and directors'  compensation,  the Company
      expects to receive a cash  dividend from the Baoding  joint  venture.  The
      board of directors of the Baoding joint venture has proposed to distribute
      a  cash   dividend  in  the  amount  of  RMB36  million   (equivalent   to
      approximately US$4,337,300) to its equity holders, although the payment of
      such dividend is contingent upon the approval by the State  Administration
      of Foreign  Exchange (SAFE),  and by the local People's  Republic of China
      (PRC) tax bureau.  In order to fulfill the cash dividend  obligation,  the
      Baoding  joint  venture plans to borrow money from a local Chinese bank by
      using its assets and its right to receive subscription fees as collateral.

<PAGE>

      The Company's  working  capital deficit at December 31, 2004 was primarily
      caused by the liability  arising out of the litigation with Gryphon Master
      Fund,  L.P.  ("Gryphon").  The  Company  has offered to settle the case by
      agreeing to the judgment on Gryphon's claim against the Company. According
      to such  offer,  the  Company  will pay to Gryphon  those  debts that were
      already  accrued and recorded  under current  liabilities in the financial
      statements for the year ended December 31, 2004. To meet this  exceptional
      cash requirement,  we are actively seeking strategic  investors in the PRC
      and intend to raise  additional  capital  through the  issuance of debt or
      equity  securities,  although  there can be no assurances  that we will be
      successful in obtaining this financing.  Meanwhile,  we will,  through our
      appointed attorney,  negotiate with Gryphon to extend the repayment period
      to allow more time for the Company to seek strategic  investors or pay the
      settlement by issuing shares of the Company's stock.

      To the  extent  that we are  unable  to  successfully  raise  the  capital
      necessary to meet our  financial  obligations  on a timely basis and under
      acceptable  terms  and  conditions,  we  will  not  have  sufficient  cash
      resources to settle  Gryphon's  claims and maintain the  Company's  normal
      operations,  and may have to dispose of our interest in the Baoding  joint
      venture and consider a formal restructuring or reorganization.

Report of Independent Registered Accounting Firm

2.    We note that your  audit  report  was  signed  by an audit  firm  based in
      California.  We also note that you conduct your operations in China,  your
      revenues  are  generated  in China and all of your  assets are  located in
      China.  Please tell us where the majority of audit work was  conducted and
      how you concluded that it is appropriate to have an audit report issued by
      an auditor licensed in California.

      RESPONSE:

      The Company's auditor, Grobstein,  Horwath & Company LLP (Grobstein), is a
      SEC practicing  accountant  firm and is registered with the Public Company
      Accounting Oversight Board (PCAOB) in the United States. Grobstein is part
      of the international  accounting network Horwath International  (Horwath).
      Grobstein  retains one of the Horwath China member firms Horwath Hong Kong
      CPA Limited (Horwath Hong Kong) to perform the audit field work in the PRC
      under  Grobstein's  direct  supervision and on-site  involvement.  Beijing
      Jingdu Certified Public  Accountant Co., Ltd. (Horwath Beijing) also signs
      off on the PRC tax provision.  Both Horwath Hong Kong and Horwath  Beijing
      are registered with the PCAOB and have received approval.

Note 4.  Summary of Significant Accounting Policies
General, page F-9

3.    Revise your  footnotes to disclose  your  functional  currency and how you
      account for the impact foreign currency has on your financial statements.

      RESPONSE:

      The Company will revise the footnotes to the financial  statements for the
      year  ended  December  31,  2004 by  including  the  accounting  policy of
      "Foreign Currency Translations and Transactions" as shown below:

<PAGE>

      "Foreign Currency Translations and Transactions

      The Renminbi  ("RMB"),  the  national  currency of the PRC, is the primary
      currency of the economic  environment in which the operations of the Joint
      Venture are  conducted.  The Company uses the United  States dollar ("U.S.
      dollars") for financial  reporting  purposes.

      The Company  translates the Joint Venture's  assets and  liabilities  into
      U.S.  dollars using the  applicable  unified  exchange rates quoted by the
      People's  Bank of China  prevailing  at the balance  sheet  date,  and the
      statement of income is translated at average unified exchange rates during
      the reporting  period.  Adjustments  resulting from the translation of the
      Joint  Venture's  financial  statements  from RMB into  U.S.  dollars  are
      recorded  in  shareholders'  equity as part of  accumulated  comprehensive
      income.

      Transactions  denominated in currencies other than RMB are translated into
      RMB at the unified  exchange rates  prevailing at the  transaction  dates.
      Gains or losses  resulting from  transactions in currencies other than RMB
      are  reflected  in the  statement  of income of the Joint  Venture for the
      reporting periods."

4.    Please tell us whether the restricted net assets of your  consolidated and
      unconsolidated subsidiaries and your Company's equity in the undistributed
      earnings of 50 percent or less owned  persons  accounted for by the equity
      method together exceed 25 percent of consolidated net assets as of the end
      of the most recently  completed  fiscal year. If restricted  net assets do
      exceed  the 25  percent  threshold,  please  disclose  what  the  specific
      restrictions are on the transfer of assets of your  subsidiaries to you in
      the form of loans,  advances  or cash  dividends  without the consent of a
      third party. If also applicable, please disclose separately the amounts of
      such   restricted   net  assets  for   unconsolidated   subsidiaries   and
      consolidated  subsidiaries  as of the end of the most  recently  completed
      fiscal year. See Rule 4-08(e)(3) of Regulation S-X.

      RESPONSE:

      The  Company  does not have  restricted  net assets for  consolidated  and
      unconsolidated  subsidiaries.  Also,  the Company  accounts for all of its
      subsidiaries, including the Baoding joint venture, on a fully consolidated
      basis.

Basis of Consolidation, pages F-9

5.    Please tell us in detail your consideration of EITF 96-16 in your decision
      to  present   consolidated   financial  results  for  the  joint  venture.
      Specifically,  tell us why Boading  Multimedia  does not have  substantive
      participating rights as defined in EITF 96-16.

<PAGE>

      RESPONSE:

      Along with the Company's  desire to provide the most meaningful  financial
      presentation,  EITF 96-16 was a primary  consideration  in its decision to
      present consolidated financial results for the Joint Venture. As stated in
      Note 4 to the financial  statements  for the year ended  December 31, 2004
      under "Basis of  Consolidation",  the amended Joint Venture agreement gave
      the Company control of the Board of Directors and the greatest  percentage
      of direct  ownership in the Joint Venture.  The agreement  states that the
      Board is the highest  authority  of the Joint  Venture and that changes in
      the Board  can only be made  after a  unanimous  vote of the  Board.  This
      follows the PRC's Sino  Foreign  Joint  Venture  law that  allows  foreign
      investors  that  are  not  majority   owners  to  have  the   "substantive
      participating rights" necessary to control the Joint Venture. Furthermore,
      the  agreement  gives  the  Company  the  right  to  fill  key  management
      positions,  including  the  position of the General  Manager who is vested
      with the  responsibility  to carry out the  decisions  of the Board and to
      organize  and be in charge  of the Joint  Venture's  daily  operation  and
      management.  Based on these  facts,  the  Company  concluded  that,  while
      Baoding Multimedia holds certain  "protective  rights",  it is the Company
      that holds the  "substantive  participating  rights" as  described in EITF
      96-16 and thus it should  consolidate  the financial  results of the Joint
      Venture.

Impairment, page F-11

6.    Revise  your  disclosure  to include how you test for  impairment  of your
      long-lived assets under SFAS No. 144. Tell us how you determined there was
      no impairment of your property and equipment and intangible assets in 2004
      and 2003.

      RESPONSE:

      In response  to the Staff  comment,  the  Company  proposes to include the
      following revised disclosure, which includes the Company's impairment test
      for its long-lived assets:

      The Company  applies the  provisions of Statement of Financial  Accounting
      Standard No. 144, "Accounting for the Impairment or Disposal of Long-Lived
      Assets"  ("SFAS No. 144"),  issued by the Financial  Accounting  Standards
      Board ("FASB").  SFAS No. 144 requires that long-lived  assets be reviewed
      for impairment  whenever events or changes in circumstances  indicate that
      the  carrying  amount  of an  asset  may not be  recoverable  through  the
      estimated  undiscounted  cash flows  expected  to result  from the use and
      eventual  disposition of the assets.  Whenever any such impairment exists,
      an impairment loss will be recognized for the amount by which the carrying
      value exceeds the fair value.

      The Company tests its long-lived assets,  including property and equipment
      and intangible assets subject to periodic amortization, for recoverability
      at least  annually or more  frequently  upon the occurrence of an event or
      when  circumstances  indicate that the net carrying amount is greater than
      its fair value.  Assets are grouped and  evaluated at the lowest level for
      their  identifiable  cash flows that are largely  independent  of the cash
      flows of other groups of assets.  The Company has  identified  this lowest
      level to be  principally  the cable TV  network  in a  specific  region of
      Baoding city.  The Company  considers  historical  performance  and future
      estimated  results in its  evaluation  of  potential  impairment  and then
      compares the  carrying  amount of the asset to the future  estimated  cash
      flows expected to result from the use of the asset. If the carrying amount
      of the asset exceeds estimated  expected  undiscounted  future cash flows,
      the Company  measures the amount of  impairment  by comparing the carrying
      amount of the asset to its fair  value.  The  estimation  of fair value is
      generally  measured by discounting  expected future cash flows as the rate
      the  Company  utilizes  to  evaluate  potential  investments.  The Company
      estimates fair value based on the information available in making whatever
      estimates,  judgments and projections are considered  necessary.  Based on
      the above impairment  tes