SecProbe.io

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Mail Stop 3561-CF/AD 11
      						August 11, 2005

Via U.S. Mail and Fax (86-752-2820298)

Mr. Albert Leung, Chief Financial Officer
Qiao Xing Universal Telephone, Inc.
Qiao Xing Science Industrial Park
Tang Quan
Huizhou City, Guangdong
People`s Republic of China 516023

	RE:	Qiao Xing Universal Telephone, Inc.
      Form 20-F for the fiscal year ended December 31, 2004
		Filed June 30, 2005
      File No. 0-29946

Dear Mr. Leung:

      We have reviewed the above referenced filing and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further review of your documents.  As such, all persons who are
responsible for the adequacy and accuracy of the disclosure are
urged to be certain that they have included all information
required pursuant to the Securities Exchange Act of 1934.
Please
address the following comments in the future filings.  If you
disagree, we will consider your explanation as to why our
comment
is inapplicable or a future revision is unnecessary.  Please be
as
detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with supplemental
information so that we may better understand your disclosure.
After reviewing this information, we may or may not raise
additional comments.

	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 look forward to working with you in these respects.  We
welcome
any questions you may have about our comments or on any other
aspect of our review.  Feel free to call us at the telephone
numbers listed at the end of this letter.

Qiao Xing Universal Telephone, Inc.
August 11, 2005
Page 2

Form 20-F for the year ended December 31, 2004

Financial statements:

Notes to consolidated financial statements

Note 19 Other acquired intangible assets, page F-31

1. Describe for us the trademarks you obtained in the
acquisition
of CECT.  Tell us how you evaluated the expected cash flows from
each significant trademark and applied the guidance in paragraph
11
of SFAS 142 in determining that the useful lives of these
intangible assets are indefinite.

2. Describe for us the methodology and significant assumptions
you
use to determine the fair value of trademarks for the annual
impairment test.

3. Expand the disclosure of your accounting policies for other
acquired intangible assets in Note 2.j at page F-14 to clarify
those intangible assets with indefinite lives are tested for
impairment annual by comparing the fair value to the carrying
amount.   Also revise the discussion of your critical accounting
policies at page 44 to describe the fair value method that you
use.
You should also address the specific uncertainties associated
with
the method, assumptions, or levels of judgment utilized in
estimating the cash flows and other assumptions required to
assess
the potential impairment long-lived assets.  Please refer to the
guidance in Release 33-8350, Commission Guidance Regarding
Management`s Discussion and Analysis of Financial Condition and
Results of Operations.

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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

Qiao Xing Universal Telephone, Inc.
August 11, 2005
Page 3

      Please respond to these comments within 10 business days
or
tell us when you will provide us with a response.  Please
furnish a
letter that keys your responses to our comments and provides any
requested supplemental information.  Please file your response
letter on EDGAR.  You may contact Gopal Dharia, Staff
Accountant,
at (202) 551-3353 or Terry French, Accountant Branch Chief (202)
551-3828 if you have questions regarding comments on the
financial
statements and related matters.  Please contact me at (202) 551-
3810 with any other questions.

							Sincerely,

							Larry Spirgel
								Assistant Director

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