SecProbe.io

Mail Stop 4561         July 21, 2008  Mr. Cheung Chi Ho Chief Executive Officer  China World Trade Corporation 5/F, Guangdong Finance Building 88 Connaught Road West Hong Kong
Re: China World Trade Corporation
 Form 10-KSB for Fiscal Year Ended December 31, 2007  File No. 000-26119

Dear Mr. Ho:

We have reviewed your filing and have the following comments.  We have
limited our review of your filing to the disclo sures pertaining to the evaluation of your
internal control over financial reporting.  Sp ecifically, we have reviewed your filing to
determine if you conducted the evaluation of  your internal cont rol over financial
reporting, as required by Exchange Act Ru les 13a-15 and 15d-15, and provided an
assessment and a conclusion as to the effectiv eness of your internal control over financial
reporting, as required by Item 308T(a) of Regul ation S-B.  Where indicated, we think you
should revise your document in response to these comments, however, if you disagree, we would be pleased to consider your explana tion as to why a revision is not necessary.
Please be as detailed as n ecessary in your explanation.
 Form 10-KSB for Fiscal Y ear Ended December 31, 2007

 Item 8A.  Controls a nd Procedures, page 48

1. It does not appear that your  management has performed its assessment of internal
control over financial reporting as of December 31, 2007.  Since you were required to file or filed an annual report for the prior fiscal year, it appears you are
required to report on your management’s assessment of intern al control over
financial reporting.

If your management has not yet performed its assessment, we ask that you complete your evaluation and amend your filing within 30 calendar days to provide the required management's repor t on internal control over financial
reporting.

Mr. Cheung Chi Ho
China World Trade Corporation
July 21, 2008 Page 2    In performing your evaluation, you may find the following documents helpful:
ƒ the Commission’s release Amendments to Rules Regarding Management’s
Report on Internal Control Over Financial Reporting  (Securities Act Release
8809/Financial Reporting Release 76).  You can find this release at:
http://www.sec.gov/rules/final/2007/33-8809.pdf ;

ƒ the Commission’s release Commission Guidance Regarding Management’s
Report on Internal Control Over Financ ial Reporting Under Section 13(a) or
15(d) of the Securities Exchange Act of 1934 (Securities Act Release
8010/Financial Reporting Release 77).  You can find this release at:
http://sec.gov/rules/interp/2007/33-8810.pdf ; and

ƒ the “Sarbanes-Oxley Section 404 – A Guid e for Small Business” brochure at:
(http://www.sec.gov/info/smallbus/404guide.shtml ).
 2. Please consider whether management’s failu re to perform or complete its report
on internal control over financial repor ting impacts its conclu sions regarding the
effectiveness of your disclosure controls  and procedures as of December 31, 2007
and revise your disclosure as appropriate.

3. We note your disclosure that your chie f executive and chief financial officers
concluded your disclosure c ontrols and procedures were  effective at a reasonable
assurance level to ensure that “material information relating to the Company is
made known to management, including the CEO and CFO, particularly during the period when [y]our periodic reports are being prepared...”  This effectiveness
conclusion is stated in terms that is mo re limited in scope than the definition of
“disclosure controls and procedures” in Exchange Act Rule 13a-15(e). The rule
requires, among other matters, that the di sclosure controls and procedures be
designed “to ensure that information require d to be disclosed by the issuer in the
reports that it files or submits under the Act . . . is recorded, processed, summarized and reported, within the time periods specified in the Commission's
rules and forms” and to ensure that “i nformation required to be disclosed by an
issuer . . . is accumulated and communicated  to the issuer's management . . . as
appropriate to allow timely decisions re garding required disclosure.”  Please
revise your disclosure to indicate whether the effec tiveness conclusions of the
CEO and CFO were made with respect to the company’s disclosure controls and
procedures as defined in Ex change Act Rule 13a-15(e).

Mr. Cheung Chi Ho
China World Trade Corporation
July 21, 2008 Page 3  4. You also disclose that “there has been no change in [y]our Internal Controls that
occurred during [y]our most recent fiscal qua rter or fiscal year that has materially
affected, or is reasonably likely to affect, [y]our Internal Controls.”  Please revise
to disclose whether or not there have been changes in your internal controls over
financial reporting  during your last fiscal quarter th at has materiall affected, or is
reasonably likely to materially affect , your internal control over financial
reporting.  See Item 308(c) of Regulation S-B.
Exhibit 31.1 and 31.2

5. We note that you filed your Principal Ex ecutive Officer and Principal Financial
Officer certifications under Item 601(b)(31) of Regulation S-B.  Such certifications should reflect the exact word ing in Item 601(b)(31) .  Please revise
these certifications as follows:
• Remove the certifying individual’s title  from the introductory sentence to
the certification;
• Replace the phrase “annual report” with the word “report” in paragraphs 2
and 3; and
• Include the introductory language of paragraph 4 and the language of
paragraph 4(b) of Item 601( b)(31) of Regulation S-B.

* * * * * * *
   Please note that the failure to perfor m management’s assessment adversely affects
the company’s and its shareholders ability to avail themselves of rules and forms that are
predicated on the current or timely filing of Exchange Act reports.  For further information regarding these impacts, please see Compliance and Disclosure Interpretation
115.02, which you can find at http://www.sec.gov/divisions /corpfin/guidance/regs-
kinterp.htm .
   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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
  We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Mr. Cheung Chi Ho
China World Trade Corporation July 21, 2008 Page 4   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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Mark Sh annon, Staff Accountant, at  (202) 551-3299 or me at
(202) 551-3408 if you have questions regarding these comments.
         S i n c e r e l y ,

         C h r i s t i n e  D a v i s          Assistant Chief Accountant