SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

        DIVISION OF
      CORPORATION FINANCE

January 18, 2011
Via U.S. Mail and Facsimile (626) 821-9361

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.
  Form 10-K for the Fiscal Year Ended December 31, 2009
Filed March 31, 2010
  File No. 1-14523

Dear Ms. Liu:
We have reviewed your response filed on November 3, 2010 and have the following
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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
 Form 10-K for the Fiscal Year Ended December 31, 2009

 Notes to Consolidated Financial Statements, page 81

 General

1. We note your response to our prior comment 6 and your conclusions that your operations
represent one operating segment and, if you were determined that your operations
represented multiple operating segments, aggregation of those operating segments into a single reportable segment would be appropriate.

Ms. Spring Liu
Skypeople Fruit Juice, Inc. January 18, 2011 Page 2

Your response indicates, in part, that you do not evaluate your business on a “separate
operating segment basis” and that your C ODM “allocates resources and reviews the
overall performance of the company as a w hole instead of individual subsidiaries”.
However, we note that the information you pr ovided in response to our specific request
for the reports your chief operating decision ma ker “reviews to make  resource allocation
decisions and to assess performance” includes information on a disaggregated basis.  Additionally, we note that MD&A in your 10-K, as well as recent earnings calls, include
discussion of operating performance on a disaggr egated basis.  Based on these factors, it
appears that there are separate components of  your enterprise that meet the definition of
operating segment in ASC paragraph 280-10-50-1.

Among other criteria, ASC paragraph 280-10- 50-11 indicates that aggregation of
operating segments is appropriate  if the segments have similar economic characteristics.
Based on the MD&A in your 10-K, as well as information in a recent earnings call, we
understand that concentrated apple and pear juices command a lower gross margin than
kiwi and other specialty concentrates.  In this  regard, we note the ta bular presentation of
gross margin percentages on page 50 of your Form 10-K for the fiscal year ended
December 31, 2009, which indicates a wide ra nge of product gross margin percentages
for both 2009 and 2008.  We also note the range of gross margin percentages on page 23
in your Form 10-Q for the nine months ended September 30, 2010.

Revise your disclosure to incl ude a presentation of segment in formation that is consistent
with the requirements of ASC Topic 280 – Segment Reporting.  Alternatively, further
explain to us why you believe your current pres entation is complies with that guidance.

2. We note your response to our prior comment 7.  Tell us if you plan to provide the
required disclosure pursuant to ASC 280-10-50-21 in future filings.
 You may contact Bob Carroll at (202) 551-3362, or  me at (202) 551-3489 if you have questions
regarding comments on the financial stat ements and related matters.
        S i n c e r e l y ,                   / s /  B r a d  S k i n n e r          B r a d  S k i n n e r         Senior Assistant Chief Accountant