SecProbe.io

Mail Stop 3628
November 16, 2009

Also via facsimile (919-719-6370)

Shah Capital Management 8601 Six Forks Road, Suite 630 Raleigh, NC 27615
Re: China Yuchai International Limited
Schedule 13D of Shah Capital Management
Filed on November 24, 2008, as amended on December 31, 2008 File No. 005-52249

Ladies and Gentlemen:

We have limited our review of your filing to those issues we have addressed in
our comments.  Where indicated, we think you should revise your document in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Item 4.  Purpose of Transaction

 1. Disclosures made by the issuer indica te that, following the most recent
amendment to your Schedule 13D, you have  engaged in activities designed to
change the issuer’s board of directors a nd bylaws.  If so, please advise why you
have not amended your Schedule 13D accordingly.

Shah Capital Management
November 16, 2009
Page 2
Item 5.  Interest in Securities of the Issuer

2. You have not described any transactions  in the subject securities in your
Schedule 13D, as amended.  Please advise.
 3. In your filings on Form 13F made follo wing the most recent amendment to your
Schedule 13D, you have reflected increases and decreases in y our holdings of the
issuer’s common stock.  In view of the a pparent activities note d above, please tell
us why you believe an amendment to your Schedule 13D was not required to reflect these changes.  We note that acqui sitions and dispositions of less than one
percent of the class of securities may be material, depending on the facts and
circumstances.  See Rule 13d-2(a) of Regulation 13D-G.

*     *     *     *     *

Please respond within 10 business days.  You should provide us with marked
copies of any amendment to expedite our revi ew.  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides any requested
information.  Detailed cover le tters greatly facilitate our re view.  Please understand that
we may have additional comments after revi ewing your amendment and responses to our
comments.
We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed investme nt decision.  Since the filing person and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy  of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a
statement from the filing person acknowledging that:
‚ the filing person is responsible for the adequacy and accuracy of the
disclosure in the filing;

‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and

‚ the filing person may not assert staff comments as a defense in any proceeding initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

Shah Capital Management
November 16, 2009 Page 3
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
You may contact me at (202) 551-3503 if  you have any questions regarding our
comments.
Sincerely,

David L. Orlic Attorney-Advisor Office of Mergers and Acquisitions