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CORRESP
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filename1.htm

    secresponse_jan302009.htm

    January
30, 2009

    BY EDGAR

    Norman
Gholson, Esq.

    Division
of Corporation Finance

    Securities
and Exchange Commission

    100 F
Street, N.E.

    Washington,
D.C. 20002

                Re:  SkyPeople
      Fruit Juice, Inc.

                File
      No. 333-149896

                Amendment
      No. 3 Filed: December 5, 2008

                Form
      10-Q Filed: November 14, 2008

                File
      No. 000-32249

    Dear Mr.
Gholson:

    Reference
is made to your comment letter, dated January 29, 2009 to our client, SkyPeople
Fruit Juice, Inc. (the “Company”), relating to Amendment No. 3 to the subject
registration statement and the Company’s Quarterly Report on Form 10-Q for the
quarter ended September 30, 2008 which was filed on November 14, 2008 (the
“Comment Letter”). We have simultaneously herewith filed an amendment to the
Company’s Quarterly Report on Form 10-Q for the quarter ended September 30, 2008
(the “10-Q/A”) which sets forth an amended and restated Item 4. Controls and
Procedures section which includes the revised language which was proposed in
Exhibit B to our letter to you dated January 14, 2009 as well as the further
revisions in response to the two comments in your Comment Letter. Set forth
below are the comments contained in the Comment Letter followed by our response
thereto.

    Form 10-Q filed November 14,
2008

    1.  We
note your response to our prior comment 7 and your proposed revised language,
which you have furnished as Exhibit B to your response letter. In the
penultimate sentence of the third paragraph, your conclusion regarding
disclosure controls and procedures doers not address the full definition as set
forth in Rule 13a-15(e). Please either delete the language beginning with “in
alerting them in a timely manner…” or provide the full definition of disclosure
controls and procedures when discussing the conclusion as to
effectiveness.

    The
language beginning with “in alerting them in a timely manner…” that was
contained in the proposed revised language in Exhibit B to our letter to you
dated January 14, 2009 has been deleted from the penultimate sentence of the
third paragraph of Item 4 of the 10-Q/A.

    2.  We
note your response to our prior comment 10. It is not appropriate to state that
“other than” certain specified items, “there was no” material change in internal
control (without qualification), or state that “there was” a material change or
“there were” material changes in internal control, and specify what the change
was, or the changes were, as the case may be.

    The
penultimate paragraph of Item 4 of the 10-Q/A has been revised from the proposed
revised language in Exhibit B to our letter to you dated January 14, 2009 to
eliminate the clause beginning with “other than” and to expressly state that
there was a change in internal control over financial reporting. Please note
that this unqualified statement had already been made in the last sentence of
the fourth paragraph of the proposed language we submitted and such sentence has
also not been changed in the 10-Q/A.

                  Very
      truly yours,

                  /s/
      Darren Ofsink

                Darren
      Ofsink