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      Largo Vista SEC Comment Response 7-21-05

    LARGO
      VISTA GROUP, LTD.

    4
      5 7 0 CAMPUS DRIVE

    NEWPORT
      BEACH, CALIFORNIA 9 2 6 6 0

    9
      4 9 - 2 5 2 - 2 1 8 0

    July
      21,
      2005

    VIA
      FAX AND EDGAR

    Mr.
      Karl
      Hiller

    Branch
      Chief

    Division
      of Corporate Finance

    U.S.
      Securities & Exchange Commission

    Washington,
      D.C. 20549

    Re:
      Largo
      Vista Group, Ltd.

    File
      No.
      000-30426

      Form
      10-KSB for Year Ended December 31, 2004

    Filed
      April 18, 2005

    Form
      10-QSB for quarters ended March 31, 2005

    Filed
      May
      11, 2005

    File
      No.
      000-31426

    Dear
      Mr.
      Hiller:

    This
      will
      acknowledge receipt of your letter of comment dated July 7, 2005 with regard
      to
      the above referenced filings. Our responses reference your comment numbers
      as
      follows:

    Comment
      1

    The
      contracts that Largo Vista Group, Ltd. (the “Company”) has with the Zunyi
      Municipal Government grant to the Company the exclusive right to supply liquid
      petroleum gas (LPG) to certain building projects and to construct or have
      constructed pipeline systems to deliver the LPG. These building projects are
      similar to large apartment or condominium complexes in the United States. The
      Company contracts with independent third parties for all of the design and
      construction of the pipelines. Generally, a central supply station will be
      built
      close to the building project to be served. LPG will be stored in this facility
      and gasified before entering the pipeline system. The Company operates these
      central supply stations and manages the relationships with the individual
      customers in the building projects. This information will be disclosed in
      greater detail in the Company’s future filings, including the Quarterly Report
      on Form 10-QSB for the fiscal quarter ended June 30, 2005 that will be filed
      shortly.

    July
      21,
      2005

    Mr.
      Karl
      Hiller

    Re:
      Largo
      Vista Group, Ltd.

    File
      No.
      000-30426

      Form
      10-KSB for Year Ended December 31, 2004

    Filed
      April 18, 2005

    Form
      10-QSB for quarters ended March 31, 2005

    Filed
      May
      11, 2005

    File
      No.
      000-31426

    Page
      two

    Comment
      2

    As
      disclosed in the subject reports and in the Company’s 8-K related to the
      contract with Shanghai Offshore Oil Group (“Shanghai Oil”), the Company received
      an assignment of the rights to receive the revenue from a contract that Shanghai
      Oil had entered into with Asiacorp Investment Holdings Ltd. (“Asiacorp”), under
      which Asiacorp is to obtain and deliver fuel oil to The Peoples Republic of
      China (“China”). Thus, the Company does not take possession of the fuel oil and
      has no responsibility for its purchase, shipment or delivery. However, the
      Company has the right to direct those activities if it chooses to do so. In
      return, the Company has agreed to provide certain consulting services to
      Shanghai Oil, including providing the benefit of the experience and the network
      of contacts of Mr. Deng Shan, Chairman of the Board of Directors of the Company,
      in the petroleum market in Asia, and to issue up to One hundred million
      (100,000,000) shares of its common stock, deliverable in equal installments
      over
      a three (3) year period to Shanghai Oil, based upon the ability of Shanghai
      Oil
      to deliver the fuel oil. None of these shares have been delivered to Shanghai
      Oil at this time.

    The
      market for fuel oil, like all other petroleum products, varies from day to
      day,
      and sometimes from hour to hour. The standard used for quotation of prices
      of
      fuel oil in China is Singapore Platt’s pricing. Shanghai Oil’s contract with
      Asiacorp guarantees that Shanghai Oil will receive a discount of Eighteen U.S.
      dollars ($18.00 US) per metric ton less than the Platt’s price at the time of
      each transaction. At today’s prices, this would give the Company at least Nine
      dollars ($9.00) per metric ton of profit; however the Company chose to cite
      the
      more conservative number of the minimum guarantee as the future market is
      unpredictable. The contract contemplates the delivery of Six million, six
      hundred ninety thousand (6,690,000) metric tons over its three (3) year
      life.

    As
      disclosed in its press release dated July 1, 2005, the Company sent to Shanghai
      Oil a
      written
      "Demand to Cure Delayed Performance" based on the failure of Shanghai Oil to
      deliver the first shipment of fuel oil that was due by May 18, 2005. As stated
      in that press release, the Company gave Shanghai Oil until July 18, 2005 to
      cure
      its failure to perform per the contract. Based upon representations of Shanghai
      Oil regarding its ability to cure its failure to perform, the Company has agreed
      to extend this date to August 31, 2005. Should Shanghai Oil fail to do so,
      none
      of the shares of the Company’s common stock mentioned above will be delivered to
      it.

    The
      one
      billion, two hundred million dollar value cited by the Company was stated to
      be
      the projected market price for the product to be delivered under the contract.
      In order to avoid confusion, in its future filings the Company will delete
      any
      reference to this number and disclose its role in the transactions in greater
      detail.

    July
      21,
      2005

    Mr.
      Karl
      Hiller

    Re:
      Largo
      Vista Group, Ltd.

    File
      No.
      000-30426

      Form
      10-KSB for Year Ended December 31, 2004

    Filed
      April 18, 2005

    Form
      10-QSB for quarters ended March 31, 2005

    Filed
      May
      11, 2005

    File
      No.
      000-31426

    Page
      three

    Comment
      3

    The
      Zunyi
      Municipal Government (“Zunyi”) agreed in its contracts with the Company to
      reimburse the Company for the costs of constructing the LPG pipelines, fifty
      percent (50%) after the signing of each contract and the remaining fifty percent
      (50%) upon completion of each pipeline project. Zunyi did pay the Company the
      first fifty percent (50%); but failed to pay the Company the remaining fifty
      percent (50%) upon completion of the first two (2) pipeline projects. Zunyi
      took
      the position that the Company should collect the balance from the customers
      as
      they subscribe for LPG delivery. The Company has been collecting that amount
      as
      a connection or subscription fee and accounting for that revenue as it is
      received.

    Because
      the Company has the exclusive right to deliver LPG to certain building projects;
      and as the building projects are occupied, the occupants must obtain their
      LPG
      for cooking and heating from the Company. The cost of electricity is prohibitive
      and regulations do not allow open fires or LPG canisters in buildings over
      one
      hundred meters tall. Meters are installed in each unit of each building project
      for billing purposes. This
      information will be disclosed in greater detail in the Company’s future
      filings.

    Comment
      4

    The
      following table shows the revenues reported by the Company for fiscal years
      2003
      and 2004 broken down by LPG Sales, Pipeline Projects and Pipeline Operations,
      in
      U. S. Dollars:

              Fiscal
                Year

              LPG
                Sales

              Pipeline
                Projects

              Pipeline
                Operations

              TOTAL

              2003

              $
                500,337

              $
                44,233

              $
                3,733

              $
                548,304

              2004

              $
                331,707

              $
                96,769

              $
                10,960

              $
                439,436

    This
      information will be disclosed in this form in the Company’s future
      filings.

    July
      21,
      2005

    Mr.
      Karl
      Hiller

    Re:
      Largo
      Vista Group, Ltd.

    File
      No.
      000-30426

      Form
      10-KSB for Year Ended December 31, 2004

    Filed
      April 18, 2005

    Form
      10-QSB for quarters ended March 31, 2005

    Filed
      May
      11, 2005

    File
      No.
      000-31426

    Page
      four

    Comment
      5

    As
      of the
      end of the period covered by the Annual Report, we conducted an evaluation,
      under the supervision and with the participation of our Chief Executive Officer
      and Chief
      Financial Officer,
      of our
      disclosure controls and procedures (as defined in Rules 13a-15(e) of the
      Exchange. Based
      upon that evaluation, the Chief Executive Officer and Chief Financial Officer
      concluded that the Company's disclosure controls and procedures were effective,
      as of the date of their evaluation, for the purposes of recording, processing,
      summarizing and timely reporting
      material information required to be disclosed in reports filed by the Company
      under the Securities Exchange Act of 1934.

    The
      Company will be sure that this is stated correctly in all future
      filings.

    Comment
      6

    Our
      independent registered accounting firm has advised us that the firm does not
      utilize an affiliate in connection with the audit of the Company’s operations in
      Zunyi, China.

    One
      of
      the firm’s senior accountants visited the Zunyi operations in connection with
      the audit of the Company’s December 31, 2004 financial statements and completed
      certain planned audit procedures under the supervision of firm personnel in
      its
      McLean, Virginia office.

    The
      accountant’s work papers and conclusions where subsequently reviewed by a firm
      supervisor and partner in the McLean, Virginia office prior to the issuance
      of
      the firm’s audit report.

    Comment
      7

    All
      of
      the statements of the certifications attached to the subject reports as Exhibits
      31.1 and 31.2 as required by Item 601(b)(31) of Regulation S-B were true and
      correct as the individuals signed their certifications. Unfortunately, minor
      language discrepancies had been interjected into the certifications prior to
      their signing. The Company will be sure that this is corrected in all future
      filings.

    July
      21,
      2005

    Mr.
      Karl
      Hiller

    Re:
      Largo
      Vista Group, Ltd.

    File
      No.
      000-30426

      Form
      10-KSB for Year Ended December 31, 2004

    Filed
      April 18, 2005

    Form
      10-QSB for quarters ended March 31, 2005

    Filed
      May
      11, 2005

    File
      No.
      000-31426

    Page
      five

    General

    The
      Company acknowledges that:

    i.
      the
      Company is responsible for the adequacy and accuracy of the
      disclosures in
      its
      filings;

    ii.
      staff
      comments or changes to disclosures in response to staff comments do
      not foreclose
      the Commission from taking any action with respect to the filings;
      and

    iii.
      the
      Company may not assert staff comments as a defense in any
      proceeding  initiated
      by the Commission or any person under the Federal securities laws of
   the
      United States.

    Should
      you have any questions, please do not hesitate to contact me or the Company’s
      counsel Mr. Philip J. Englund, 3460 Corte Clarita, Carlsbad, CA 92009,
      760-753-7400, fax 760-753-7410. Please copy Mr. Englund on any further
      correspondence. Thank you.

    Very
      truly yours,

    /s/
      Deng
      Shan

    Deng
      Shan

    Chief
      Executive Officer and

    Chairman
      of the Board of Directors