SecProbe.io

August 19, 2010

Ms. Spring Liu Chief Financial Officer SkyPeople Fruit Juice, Inc. 16F, National Development Bank Tower No. 2 Gaoxin 1
st Road
Xi’an, People’s Republic of China
Re: SkyPeople Fruit Juice, Inc.
  Amendment No. 5 to Registra tion Statement on Form S-1
Filed August 19, 2010
  File No. 333-166194

Dear Ms. Liu:
 We have limited our review of your registra tion statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Amendment No. 5 to Registration Statement on Form S-1

 Use of Proceeds, page 34

 1. We note your response dated August 16, 2010 to our prior oral comment.  We note that in
your “Use of Proceeds” section, you mention “income from government subsidies” on
page 35.  Please add a cross-reference to th e discussion of “Government Grants” on page
42.
 2. You provide a table of “Priorit y Projects” (the first table on page 34).  The fourth item on
that table is $6.7 million for “Huludao Wonde r—construction and environmental project
expenses.”  This item appears before any of the Qiyiwangguo projects.  Yet the “Capital
Expenditure Projects” table (the second table on page 34) indicates that you do not intend
to use any of the offering proceeds for this it em.  Please clarify whether or not the items
in the “Priority Projects” table are listed by priority.  If so, explain why you will spend

Ms. Spring Liu SkyPeople Fruit Juice, Inc.
August 19, 2010 Page 2

proceeds on the Qiyiwangguo projects before you spend on the “Huludao Wonder – construction and environmental project expenses” item.
 3. With regard to your “Capital Expenditure Proj ects” table, you state that:  “The following

table presents our current estimated allo cations of such proceeds, which includes
approximately $24.8 million for projects at Huludao Wonder facility and approximately $21.5 million for projects at Qiyiwangguo facility [emphasis added].”  This is imprecise,
because $24.8 million and $21.5 million are the a ggregate totals for the Huludao Wonder
projects and the Qiyiwangguo proj ects, respectively, as set fort h in the “Priority Projects”
table above.  By contrast, the “Capital Expenditure Proj ects” table only includes $18.1
million relating to Huludao Wonder projec ts and a range of $12.5 million to $17.1
million relating to Qiyiwangguo projects.  Please clarify.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  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.
Notwithstanding our comments, in the event you request acceleration of  the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

• the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.

Ms. Spring Liu SkyPeople Fruit Juice, Inc. August 19, 2010 Page 3

Please contact Norman von Holtzendorff at  (202) 551-3237 or me at (202) 551-3611 with
any questions.
Sincerely,
      Anne Nguyen Parker
Branch Chief