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      Largo SEC Comment Response 2 8-19-05 number 2

    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

    August
      19, 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
      is
      written in response to the comments and requests made by you and Ms. Lilly
      Dang
      in our telephone conversation of August 1, 2005. In addition to the items that
      Largo Vista Group, Ltd. (“Largo” or the “Company”) agreed in my letter to you
      dated July 21, 2005 would be addressed in future filings made by the Company,
      we
      propose to amend the subject filings to include the disclosures discussed
      below.

    As
      we
      discussed, the Company obtained from Shanghai Offshore Oil Group (HK) Co.,
      Ltd.
      (“Shanghai Oil”) the rights to the revenues generated from Shanghai Oil’s
      contract with Asiacorp Investment Holdings Ltd. (“Asiacorp”) to obtain and
      deliver fuel oil to The Peoples Republic of China (“China”). That contract,
      attached as an exhibit to the Company’s 8-K filed on March 31, 2005 and
      incorporated by reference into the subject filings, calls for delivery of thirty
      thousand (30,000) metric tons per month of fuel oil in the first three (3)
      months of the contract and two hundred thousand (200,000) metric tons per month
      of fuel oil in the remaining thirty-three (33) months of the contract, for
      a
      total commitment of six million, six hundred ninety thousand (6,690,000) metric
      tons of fuel oil. The Company’s agreement with Shanghai Oil guarantees that the
      Company will realize a profit of two dollars ($2.00) per metric ton of fuel
      oil.
      Although the discount of eighteen dollars ($18.00) per metric ton from the
      standard pricing of

    August
      19, 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

    fuel
      oil
      in China based on Singapore Platt’s that is provided in the Shanghai Oil
      contract with Asiacorp would generate much more that this minimum guarantee
      at
      today’s prices, the Company has chosen to cite the minimum guarantee in its
      disclosures. This would generate a minimum of thirteen million, three hundred
      eighty thousand dollars ($13,380,000) in revenues to the Company over the three
      (3) year period.

    As
      we
      also discussed, the Company promised consideration for the assignment of this
      revenue stream is up to one hundred million (100,000,000) shares of the common
      stock of the Company, deliverable in equal installments over the three (3)
      year
      term of the contract, based on actual deliveries of the fuel oil. In addition,
      although not set forth in the Shanghai Oil contract itself, I have agreed to
      provide consulting services to Shanghai Oil which will prove to be very valuable
      to them in, among other things, identifying customers for the fuel oil as I
      have
      developed many contacts in and great knowledge of the market for petroleum
      products in China. However, because the consulting services are not provided
      for
      in the Shanghai Oil contract itself, the Company will account for all funds,
      if
      and when received from the sale of the fuel oil as a capital transaction
      .

    Based
      upon the Company’s discussion of these matters in my letter to you dated July
      21, 2005, our telephonic discussion of August 1, 2005 and the discussion above,
      the Company proposes to amend its subject filings, replacing its disclosures
      regarding the Shanghai Oil contract with the following:

    On
      March
      18, 2005, Largo Vista signed an Agreement and Assignment of Certain Contractual
      Rights and Benefits (the “Agreement”), with Shanghai Offshore Oil Group (HK)
      Co., Ltd. (“Shanghai Oil”). Under the Agreement, Shanghai Oil assigned to Largo
      Vista all of its rights under a prior contract with Asiacorp Investment Holding
      Ltd. to purchase fuel oil produced in Russia and deliver it to entities in
      The
      People’s Republic of China (the “Asiacorp Contract”). The Agreement states that
      deliveries will begin no later than May 18, 2005 at a rate of thirty thousand
      (30,000) metric tons per month for three (3) months and continue for the
      following thirty-three (33) months at a rate of two hundred thousand (200,000)
      metric tons per month, for a total of six million, six hundred
      ninety

    August
      19, 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

    thousand
      metric tons. The Asiacorp Contract provides that the price paid for the fuel
      oil
      will be eighteen dollars per metric ton less than the normal market price of
      fuel oil in China, which is based on Singapore Platt’s pricing quotations. The
      Agreement provides that Largo Vista will be guaranteed a minimum payment of
      two
      dollars ($2.00) per metric ton, and that Shanghai Oil will continue to be
      responsible for the logistics and financing of the delivery of the fuel oil.
      Although the discount provided in the Asiacorp Contract should generate greater
      profits from the sale of the fuel oil, at the two dollars ($2.00) per metric
      ton
      guaranteed in the Agreement, the full amount of fuel oil contemplated to be
      delivered in the Asiacorp Contract would generate payments to Largo Vista of
      thirteen million, three hundred eighty thousand dollars ($13,380,000) over
      the
      three (3) year period of the Asiacorp Contract. In exchange, Largo Vista will
      issue to Shanghai Oil one hundred million (100,000,000) shares of Largo Vista’s
      common stock, to be issued in three increments over the term of the Agreement,
      based upon Shanghai Oil’s actual deliveries of the fuel oil. Funds received by
      Largo Vista from the sale of the fuel oil, if any, and the issuance of our
      common shares, will be accounted for as a capital transaction .As of the date
      of
      this amended filing, Largo Vista has not received and nor delivered any oil
      under the Asiacorp Contract. Largo Vista has not released any of its shares
      of
      common stock to Shanghai Oil under the Asiacorp contract. As a result, Shanghai
      Oil is in default under the terms of the Asiacorp Contract. Largo Vista has
      formally notified Shanghai Oil of the default and has given Shanghai Oil until
      August 30 to cure its default. Although Shanghai Oil has assured Largo Vista
      that Shanghai Oil intends to perform on the contract, notwithstanding the
      current default, Largo has not independently verified that Shanghai Oil has
      the
      means to deliver on the contract and investors should understand that delivery
      is not certain.

    August
      19, 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

    In
      addition, Largo Vista proposes to add the following disclosure to the Subsequent
      Events section of the amendments to each of the subject filings:

    In
      August
      2005, the staff of the Los Angeles office of the Securities and Exchange
      Commission advised Largo Vista that it had initiated a formal, non-public
      inquiry.  Largo Vista and its officers have received document
      subpoenas seeking documents related to the previously announced contract between
      Largo Vista and Shanghai Oil and trading in the securities of Largo Vista,
      among
      other things.

    While
      the
      Company is confident in its practices, there is a risk that an enforcement
      proceeding will be recommended by the staff of the Commission as a result of
      this formal investigation. An enforcement proceeding could include allegations
      by the SEC that the Company and/or its officers violated,
      among
      others, the anti-fraud and books and records provisions
      of
      federal securities laws, and the rules thereunder. It cannot be predicted
      with certainty what the nature of such enforcement proceeding would be, the
      type
      of sanctions that might be sought, or what the likelihood would be of reaching
      settlement. The Company has been and expects to continue to cooperate with
      the
      ongoing SEC investigation.

    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.

    August
      19, 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

    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

    Acting
      Chief Executive Officer and

    Chairman
      of the Board of Directors