SecProbe.io

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FANTAWILD                        FANTATECH INC.
[GRAPHIC OMITTED]

   Suite 1A, 18/F, Tower 1, China Hong Kong City, 33 Canton Rd., Tsimshatsui,
     Kowloon, Hong Kong     Tel: (852) 2302 1636     Fax: (852) 2890 8672

                                                July 6, 2005

VIA EDGAR AND FEDERAL EXPRESS
-----------------------------

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington DC,  20549

Attn.:    Linda Cvrkel
          Jean Yu

          RE:  FANTATECH, INC.
               FORM 10-KSB FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004
               FILE NO. 000-24374

Ms. Cvrkel and Ms. Yu:

On  behalf of Fantatech, Inc. (the "Company"), I enclose our replies in response
to  the  comments  received  from  the  staff  of  the  Securities  and Exchange
Commission  ("Staff")  in  their letter dated May 18, 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.

Form 10-K for the Fiscal Year Ended December 31, 2004
-----------------------------------------------------

Item 2 - Description of Properties, page 13
-------------------------------------------

1.   We  note that your principal executive offices are leased free of rent from
     a  related  company  controlled  by  SHQ.  We  also  note  the chairman and
     president  of  SHQ is also the CEO and chairmen of the Company. However, it
     is  unclear  how you have accounted for such expenses incurred on behalf of
     Fantatech  by  the  related company. Note that all costs of doing business,
     including  costs  incurred  by  principal  shareholders  or similar related
     parties,  should be reflected in the historical financial statements. Refer
     to  the guidance outlined in SAB 5.T. Please quantify for us and explain in
     detail  how  the costs were accounted for within your financial statements.
     If  the  amounts  were not material, please specifically state so in future
     filings. We may have further comment upon receipt of your response.

<PAGE>
     Response:
     ---------

     The  Company  intended  to relocate its principal executive offices to Hong
     Kong  in  order  to enhance its linkage to its major business operations in
     the PRC. The decision to relocate the Company's principal executive offices
     was  made  in  late  December 2004 and, while the Company was looking for a
     suitable  office  venue,  the  rent-free  lease  was  set-up  as a bridging
     arrangement.

     From  December  2004  through  June  23, 2005, the Company had not utilized
     these  facilities except as a postal address, since the property is located
     at  a  residential district rather than a commercial district. Accordingly,
     the  value of such rent was not material, and the Company therefore did not
     account  for any expenses related to its principal executive office in Hong
     Kong  in  2004  and  in  the  first  quarter  of  2005.

     Effective from June 23, 2005, the Company has moved its principal executive
     office  to an office building located in one of the commercial districts in
     Hong  Kong.  The  Company will occupy approximately a quarter of the office
     space  which  is  provided by a related company controlled by SHQ, and will
     share  the  proportional  costs  of  $1,000 per month plus other incidental
     expenses  such  as  electricity,  office  supplies,  etc.

     The  Company  is  aware  of  the importance to recognize all costs of doing
     business  and  will  record and disclose in detail the related costs in its
     future  filings,  including any related party aspects. The expenses related
     to  the  CEO  and  Chairman  are  discussed  in  comment  9  below.

Item 6 - MD&A
-------------

Overview, page 15
-----------------

2.   Reference  is  made  to  the  last  paragraph  on page 15.  We believe your
     disclosure  regarding your foreign currency translation policy is confusing
     and  requires revision. For example, you state that the functional currency
     of  the  Company's  PRC operations is the Renminbi. You also state that the
     accounts  of  foreign  operations  are prepared in their local currency and
     translated  into  USD  at  the  applicable rate of exchange. However, it is
     unclear  whether you are referring to foreign operations other than that of
     PRC  and  if  so,  whether  the  local  currency of such foreign operations
     represents  the  functional currency in accordance with paragraph 5 of SFAS
     No.  52.  Further, it is unclear how applicable exchange rates are defined.
     Please  clarify  for  us in the MD&A and notes to the financial statements,
     and  how your treatment complies with the guidance outlined in SFAS No. 52.

                                                                         2 of 21
<PAGE>
     Response:
     ---------

     The  description  "The accounts of foreign operations are prepared in their
     local  currency  and  are  translated into USD using the applicable rate of
     exchange"  was  repetitive.  This  statement  actually  referred to the PRC
     operations since the Company's other subsidiaries in the US and BVI adopted
     USD  as  their  functional  currency.

     The  Company  proposes  to  change its relevant description in MD&A and the
     notes to the financial statements in its future filings as follows:

     "The  Company's  PRC  subsidiaries maintain their financial records and the
     statutory financial statements in Renminbi ("RMB"), the functional currency
     and  official  currency of the PRC. Revenue and expenditures denominated in
     currencies  other  than  RMB  are  translated  into  RMB  at the prevailing
     exchange  rate  when  recognized and recorded in the PRC financial records.
     Monetary  assets  and  liabilities denominated in other currencies are also
     translated  into  and  recorded  in  RMB  at  the  balances sheet date. Any
     transaction  gain  or loss is charged to the statement of operations of the
     PRC  subsidiaries  in the period in which such gain or loss occurs. The PRC
     accounts denominated in RMB are then translated into the reporting currency
     (USD)  using  the  exchange  rate  prevailing at the balance sheet date for
     consolidation  and  presentation."

     "The  financial  statements  are  translated  from  RMB  to USD at a single
     exchange  rate  of  US 1.00 to RMB 8.3 as of December 31, 2003 and December
     31,  2004.  Since the exchange rate has remained fixed during such periods,
     there  is  no  resulting  translation  gain  or loss recorded as a separate
     component  of  stockholders'  equity".

3.   We  also  note  that  you  disclose  transactions denominated in currencies
     other than in U.S. dollar are translated into U.S. dollar at the applicable
     exchange  rates.  Note  that  foreign  currency transactions are defined as
     transactions  denominated  in a currency other than the entity's functional
     currency  (i.e.  Renminbi),  and  not  its  reporting  currency.  Further,
     transaction  gains  and  losses,  which  arise from changes in the exchange
     rates  of  the  foreign currency and functional currency (measured from the
     transaction  date  and subsequent settlement), are realized upon settlement
     of the foreign currency transaction and generally should be included in net
     income  (loss)  in the period in which the transaction is settled. However,
     translation  adjustments  which  result  from  translating  the  entity's
     financial  statements  into  its  reporting  currency  are  not included in
     determining  net  income  (loss)  but  rather  are  reported  in  other
     comprehensive  income  (loss).  In  this  regard,  please  tell  us  why
     transactions  denominated  in  currencies  other  than  in  U.S. dollar are
     translated  into  U.S. dollar rather than the functional currency. Refer to
     paragraphs  15  and  16  of  SFAS  No. 52. Also, supplementally explain why
     translation  gains  and  losses are credited or charged to the consolidated
     statements of operations rather than reported as a component of

                                                                         3 of 21
<PAGE>
     other  comprehensive  income  in  the  statements  of  shareholders' equity
     pursuant  to  the  guidance  in  paragraph  13  of SFAS No. 52. We may have
     further  comment  upon  receipt  of  your  response.

     Response:
     ---------

     The description that "Transactions denominated in currencies other than the
     U.S.  dollars  are  translated into U.S. dollars at the applicable exchange
     rates" referred to those operations outside of the PRC, specifically the US
     and BVI subsidiaries. Transactions denominated in currencies other than the
     functional currency (USD) of the subsidiaries are converted into USD at the
     prevailing  exchange  rates  at  the date of the transaction or settlement.

     No  actual transaction gains or losses had been charged to the consolidated
     statements  of  operations.  The  description  was  meant  to  refer to the
     relevant exchange gains or losses of the respective subsidiaries that would
     be  charged  to  the statement of operations of the respective subsidiaries
     (rather  than  the  consolidated  statements  of operations) if applicable.

     The  Company  proposes to add disclosure in MD&A and the notes to financial
     statements  in  future  filings  as  follows:

     "The  Company's  other  subsidiaries in the US and BVI adopted USD as their
     functional  currency. Transactions denominated in currencies other than the
     functional  currency  of  these  subsidiaries  are  converted  into  their
     functional  currency  at  the  prevailing  exchange  rates  at  the date of
     transaction  or  settlement.  No  further  translation  of currency is thus
     required ".

Consolidated Results of Operations
----------------------------------
Fiscal Years Ended December 31, 2004 and 2003
---------------------------------------------

Revenue, Page 16
----------------

4.   We  note  that  net  contracted  sales  increased by $3,479,562 or 75.5% as
     compared  to  fiscal  2003.  You  disclose  this was due to the substantial
     increase in the number of projects attributable to the successful marketing
     strategies  implemented  by the Company. In this regard, please tell us and
     revise  future  filings  to  quantify the incremental amount of revenue and
     number  of  projects attributable to the successful marketing strategies in
     comparison  to  prior  year.  Further, we also note that compared to fiscal
     2003,  contracted  rates from customers outside of PRC declined from 21% to
     93%  in  fiscal  2004. Please tell us and revise future filings to disclose
     the  reason(s)  for the decrease in contracted sales from customers outside
     of  PRC.

                                                                         4 of 21
<PAGE>
     Response:
     ---------

     The Company proposes to make the following changes in future filings:

     For  the  year  ended  December 31, 2004, net contracted sales increased by
     $3,479,562  or  75.5% to $8,088,290, as compared to $4,608,728 for the year
     ended  December 31, 2003. This was primarily attributable to the successful
     marketing  strategies  implemented  by  the Company, although the number of
     contracted  projects  decreased  from  25  in 2003 to 21 in 2004, the total
     amount  of  contracted  sales  increased  by  $3,479,562,  representing  an
     increase  in  average  contract  amount of $200,808 per contract in 2004 as
     compared  to  the  average  contract  amount  of  $184,349  in  2003.

     During  the  year  of  2004, approximately 9.3% of the Company's contracted
     sales  were  from  customers outside of PRC as compared to 21% in 2003. The
     decrease  was  mainly  attributable  to  the  reduced  marketing  resources
     allocated  for  overseas  sales  due  to  lower  sales margins from markets
     outside  of  PRC  (averaged gross contribution per contract was $64,900 and
     $85,780 in 2004 and 2003, respectively) when compared with the sales in PRC
     (averaged gross contribution per contract was $184,350 and $112,175 in 2004
     and  2003, respectively). The Company also received fewer orders in 2004 (2
     contracts)  from  customers  outside  of  PRC  than  in 2003 (7 contracts).

Gross Profit, page 16
---------------------

5.   Please  revise  future  filings  to  describe the significant components of
     costs  of sales. Specifically, tell us and describe the types of costs that
     comprise direct costs of sales and other costs of revenue - RSO (e.g. rent,
     employee  salaries,  depreciation,  etc.)  as presented on the face of your
     consolidated  income  statement.

     Response:
     ---------

     The Company proposes to add the following disclosure in future filings:

     For  the year ended December 31, 2004, total gross profit was $3,225,428 or
     38.4%  of  total net sales, as compared to total gross profit of $1,696,927
     or 36.3% of total net sales for the year ended December 31, 2003.

     Cost  of sales mainly consisted of raw materials, electronic parts, factory
     consumables,  sub-contracting  charges  and  related supplies purchased for
     fabrication  and  assembling  of  the  amusement  equipment,  factory rent,
     workers  wages and salaries, and the depreciation of production facilities.
     Other costs of revenue for revenue-sharing operations included depreciation
     for  the  fixed  assets used in the operations, maintenance costs, salaries
     for engineers, and the associated traveling and lodging expenses.

     Net  of the effect from the revenue-sharing operations, gross profit margin
     improved  by

                                                                         5 of 21
<PAGE>
     4.2%,  which was primarily due to the slightly better contribution provided
     from  certain  large  contracts  entered  into  during  2004.

6.   Please  supplementally  quantify  and  describe  the  nature of the initial
     operating  expenses  that  were  incurred  a few months prior to the formal
     opening  of  the six new Funplexes that were launched in fiscal 2004. Also,
     similarly  revise your disclosure in future filings. Supplementally tell us
     how  you accounted for the initial operating expenses within your financial
     statements  and  why  you  believe  you  treatment  is  appropriate.

     Response:
     ---------

     The Company proposes to add the following explanation in future filings:

     During  the  year  ended  December  31,  2004,  total  gross  loss  from
     revenue-sharing  operations  was  $4,744  or  (1.5%)  of  the total segment
     revenues,  as  compared  to  total  gross profit of $48,918 or 69.3% of the
     total  segment  revenues  for  the year ended December 31, 2003. The slight
     loss recorded in 2004 on the revenue-sharing operations was attributable to
     the  less  than  full  year  operation  of the six new FunPlexes funded and
     launched  by the Company in 2004, with the initial operating expenses being
     incurred  a  few  months  earlier  than  their  formal  opening.

     For  the  year  ended  December  31,  2004,  the initial operating expenses
     incurred  for the six Funplexes were RMB285,763 or $34,429, which consisted
     of costs associated with the wages and traveling expenses for engineers and
     workers  to  perform  the on-site installation, commissioning and trial run
     befor