SecProbe.io

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							May 17, 2005

By U.S. Mail

Mr. Man Keung Wai, Chief Executive Officer
CHINAWE.COM, INC.
Room 7, 13/F, Block A
Fuk Keung Industrial Building
66-68 Tong Mi Road
Kowloon, Hong Kong

	Re:	Chinawe.com, Inc.
Annual Report on Form 10-KSB (fiscal year ended December 31, 2004)
		Filed: April 14, 2005
		File No. 0-29169

Dear Mr. Wai:

	We have reviewed the above referenced filing based upon an
examination restricted solely to considerations of Selected
Financial
Data, Management`s Discussion and Analysis, and the Financial
Statements and have the following comments.  Where indicated, we
think you should revise your document in response to these
comments
in an amendment to the December  31, 2004 Annual Report on Form
10-
KSB.  Please confirm that such comments will be complied with.  If
you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  After reviewing the
information, we may or may not raise additional comments.

	Pursuant to Rule 101(a)(3) of Regulation S-T, your response,
should be submitted in electronic form, under the label "corresp",
and be provided within ten (10) business days from the date of
this
letter, and an amendment to the Form 10-KSB should be filed within
15
business days from the date of this letter.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
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.

May 17, 2005

Mr. Man Keung Wai
Chinawe.com, Inc.
Page 2

FORM 10-KSB (Fiscal Year Ended December 31, 2004)

Management`s Discussion and Analysis

Year Ended December 31, 2004 Compared to the Year Ended December
31,
2003, page 5

1. Please reclassify the amount of fiscal year 2004 `write-back of
rental expenses overprovided` from non-operating income to
inclusion
within `operating expenses` on the statements of operations or
supplementally support your current presentation.  Also provide an
explanation as to the facts and circumstances that resulted in
rental
expense being overprovided in the previous year.

Liquidity and Capital Resources, page 6

2. Disclose whether or not you have any available credit
facilities
or any commitments from shareholders, directors or officers to
provide advances, loans or other financing to you.  In this
regard,
we note from the financial statements that related parties have
provided you with advances to finance your operations.  Please
provide discussion of the dependence on this source of financing.

Financial Statements

Note 2 (a)  Basis of Accounting, page F-6

3. We see that you are a domestic issuer, incorporated in
California.
Domestic registrants must report in US dollars unless they are
organized under laws of a foreign country.  Please revise your
financial statements accordingly or advise.

Other

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

May 17, 2005

Mr. Man Keung Wai
Chinawe.com, Inc.
Page 3

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company 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 any action
with
respect to the filing; and

* 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

Closing

      You may contact Ms. Beverly A. Singleton, Staff Accountant,
at
(202) 551-3328, or Ms. Margery Reich, Senior Staff Accountant, at
(202) 551-3347 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3211 with any other questions.

      Sincerely,

							David R. Humphrey
							Accounting Branch Chief

c/o:	Mr. Joel I. Frank, Esq.
	Hartman & Craven LLP
	via Facsimile (212) 688 - 2870
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