SecProbe.io

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                        SCHNEIDER WEINBERGER & BEILLY LLP
                                Attorneys-at-Law
                    2200 Corporate Boulevard, N.W., Suite 210
                         Boca Raton, Florida 33431-7307

                                                                  Telephone
James M. Schneider, P.A.                                         (561) 362-9595
Steven I. Weinberger, P.A.                                         Facsimile
Roxanne K. Beilly, P.A.                                          (561) 362-9612

                                 October 5, 2005

VIA FASCIMILE (202) 772-9217
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C.  20549

         Attention:        Jeffrey Riedler
                           Dana Hartz
                           Joel Parker
                           Zafar Hasan

         Re:      Sunwin International Neutraceuticals, Inc. (the "Company")
                  Verbal Comment on October 4, 2005 to Amendment No. 2 to the
                  Registration Statement on Form SB-2
                  File Number 333-125300

Ladies and Gentlemen:

         Today the Company received the last comment from the Staff, pursuant to
a verbal comment from Dana Hartz, pertaining to amendment number 2 to the
Registration Statement of the Company. The comment was as follows:

         1. We note your response to comment number 6 of our September 16, 2005
comment letter to clarify the accounting treatment of the amount due from
related parties, supplementally please tell us how your response supports
current asset classification under ARB 43, chapter 3a paragraphs 4-6

         RESPONSE: After analysis of ARB 43, chapter 3a paragraphs 4-6, the
Company has amended its balance sheet to show the amounts due from related
parties for leasehold improvements, construction in process and equipment as
long-term assets and amended its statement of cash flow to adjust accordingly
amounts for investing activities.

         In addition, given the revisions to the financial statements, upon
review of the registration statement these revisions necessitate the Company to
revise the "Selected Financial Data" information on page 3 and the MD&A section
on pages 24 through 26. The Company does not believe that the disclosure within
the registration statement describing the "amounts due from related parties"
needs to be revised.

         Lastly, we have also updated certain unrelated information contained in
the registration statement in connection with the sections "Selling
Securityholders" due to sales of the shares under rule 144, and "Our History"

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due to the termination of a letter of intent, and general pagination.
Accordingly, I am attaching hereto for your review prior to the filing of
amendment no. 3 the revised pages in the financial statements and registration
statement that contain the revisions, marked to show the changes, along with the
cover page for the registration statement and prospectus.

         The Company wishes to confirm that the Staff has no further comments
before filing amendment no.3 containing these revisions, and appreciate your
review of the facsimile pages.

         If you have any further questions or comments, please contact the
undersigned.

                                                              Very truly yours,

                                                              Roxanne K. Beilly
cc: Dongdong Lin

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