SecProbe.io

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						October 11, 2005

Room 4561

Ms. Angela Du
Chief Executive Officer
China Mobility Solutions, Inc.
#900-789 West Pender Street
Vancouver, B.C. Canada V6C 1H2

	Re:	China Mobility Solutions, Inc.
		Registration Statement on Form SB-2
		Filed September 14, 2005
		File No. 333-128323

		Form 10-KSB for the fiscal year ended December 31, 2004
		Form 10-QSB for the quarter ended March 31, 2005
		Form 10-QSB for the quarter ended June 30, 2005
		File No. 0-26559

Dear Ms. Du:

	We have limited our review of your filings to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your documents in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please respond to our
comments regarding your Form 10-KSB and Forms 10-QSB within 10
business days of the date of this letter.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may 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
filings.
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.

Registration Statement on Form SB-2

General

1. As you know, our accounting staff issued comments regarding the
company`s financial statements in a letter dated July 7, 2005.
Please note that this registration statement will not be declared
effective until you have complied with both the comments issued in
connection with the filing of your registration statement, which
are
discussed below, and the comments of our accounting staff.
2. We note from Section 1(b) of the Form of Debenture filed as
exhibit 4.1 to the registration statement that holders of the
debentures may, in their sole discretion, elect to receive
interest
payments in either common stock or cash.  Given this discretion on
the part of the investors, please tell us why you believe that the
offer and sale of the interest shares was complete when you filed
the
registration statement?

3. Please revise throughout your filing as necessary to remove any
references to the "NASD OTCBB."  Instead, you may refer to the
OTCBB
and include an explanation indicating that it is maintained by
NASD.

Prospectus Front Cover Page

4. Your disclosure on pages 35 and 38 of the registration
statement
appears to indicate that you are registering the resale of shares
that were previously sold in a best efforts offering.  However,
the
front cover page of your prospectus indicates that the
registration
statement covers the offering of shares by Meyers Associates on a
"best efforts" basis.  Please revise both your cover page and any
related disclosure throughout the filing to clarify, if true, that
the registration statement relates to the resale of common stock
by
the selling shareholders, or advise.

Selling Stockholders, page 35

5. All material transactions between the company and the selling
stockholders should be disclosed in this section, including the
material terms of the transactions by which the selling
stockholders
received the shares being offered for resale.  See Item 507 of
Regulation S-B.  Please revise this section accordingly to provide
information with respect to the transactions by which the selling
stockholders received their shares.  Additionally, we note from
your
disclosure on page II-3 that you relied on Sections 4(2) and 4(6)
of
the Securities Act, and Rule 506 of Regulation D in conducting
your
units offering.  Please revise "Recent Sales of Unregistered
Securities" to clarify, if true, that all the purchasers were
accredited.

6. Please disclose the individual or individuals who exercise the
voting and dispositive powers with respect to the shares to be
offered for resale by all non-reporting legal entities.  If any
selling stockholder is controlled by a public company, you may
revise
to identify the public company as the entity that exercises such
voting and dispositive powers.  See Interpretation I.60 of the
July
1997 manual of publicly available CF telephone interpretations, as
well as interpretation 4S of the Regulation S-K portion of the
March
1999 supplement to the CF telephone interpretation manual.

7. If any of the selling stockholders are registered broker-
dealers,
other than selling stockholders who received their shares as
compensation for investment banking/placement agent services, such
selling stockholders should be named as underwriters with respect
to
the shares they are offering for resale.  Additionally, if any
selling stockholders are affiliates of a broker-dealer, please
disclose, and tell us whether the selling stockholders received
their
shares in the ordinary course of business and whether, at the time
of
acquisition, they had any understandings or arrangements with any
other person, either directly or indirectly, to distribute the
shares.

Plan of Distribution, page 38

8. We note that the second to last paragraph of this section
indicates that Meyers will not participate in any capacity under
this
resale prospectus and distribution.  However, Meyers appears to be
named as a selling shareholder.  Please revise to clarify.

Signatures
9. The Instructions for signatures portion of Form SB-2 requires
that
your registration statement be signed by the CEO, as well as by
the
CFO and the controller or principal accounting officer.  Please
ensure that your next amendment is revised accordingly.

Legal Opinion

10. Your legality opinion states that counsel`s opinions are
limited
to the internal laws of the State of New York and the federal laws
of
the United States of America even though the registrant - China
Mobility Solutions, Inc. - is a Florida corporation.  Further, the
opinion expressly states that counsel is not admitted to practice
in
the State of Florida and that no opinion is expressed as to the
laws
of the State of Florida.  For purposes of rendering its opinion,
counsel assumes that the laws of the State of Florida are the same
as
the laws of the State of New York.

As you know, counsel is permitted to opine on the laws of the
states
in which they are admitted to practice.  Moreover, all lawyers are
capable of opining on Delaware law.  We also accept an opinion of
counsel on a jurisdiction in which counsel is not admitted to
practice so long as the opinion is not qualified to jurisdiction.
We
believe that your legality opinion is qualified as to
jurisdiction.
Please revise.

11. We note that while your counsel has opined that the Shares are
lawfully and validly issued, as well as fully paid and non-
assessable, with respect to the Warrant Shares and Debenture
Shares,
they have only opined that such shares will be fully paid and non-
assessable.  As Item 601(b)(5) of Regulation S-B requires that
your
legal opinion address whether all of the shares covered by the
registration statement are legally issued, as well as fully paid
and
non-assessable, ensure that your revised opinion addresses whether
the Warrant and Debenture Shares will be legally issued at the
time
of exercise or conversion.

Form 10-QSB for the quarter ended March 31, 2005

Controls and Procedures, page 7

12. We note that as of the end of your first quarter, management
identified a material weakness in your disclosure controls and
procedures regarding the fact that your internal controls and
procedures manual at that time was not based upon a recognized
internal control framework.  Please revise to disclose when this
material weakness was identified.  Additionally, tell us whether,
in
light of the discovery of such material weakness, management
continues to believe that its disclosure controls and procedures
were
effective as of the end of your fiscal year ended December 31,
2004.
Additionally, please revise to disclose whether the material
weakness
had an effect on the company`s financial statements.

13. We note your statement that "[e]xcept as noted above," there
were
no changes in your internal control over financial reporting
during
your first fiscal quarter.  Revise to state clearly, if correct,
that
there were changes in your internal control over financial
reporting
that occurred during the quarter that materially affected, or are
reasonably likely to materially affect, your internal control over
financial reporting, and clearly indicate the changes that were
made.
For example, we note that your Form 10-QSB for the quarter ended
June
30, 2005 indicates that your disclosure controls and procedures
were
effective as of the end of that quarter.  Revise your Forms 10-QSB
as
appropriate to indicate when and how the material weakness was
cured.
If the material weakness was rectified in your second fiscal
quarter,
we would expect to see disclosure indicating that there were
changes
in your internal control over financial reporting during such
quarter
that related to alleviating the material weakness.

Form 10-QSB for the quarter ended June 30, 2005

Controls and Procedures, page 7

14. We note that the last paragraph of this section indicates that
there were no changes in the company`s internal control over
financial reporting that could have "significantly affected those
controls subsequent to the date of the evaluation."  However, the
standard set forth in Item 308(c) of Regulation S-B requires that
you
disclose any change in internal control over financial reporting
that
occurred during your last fiscal quarter that has materially
affected, or is reasonably likely to materially affect, your
internal
control over financial reporting.  If you continue to believe that
there were no changes in your internal control that occurred
during
the quarter ended June 30, 2005, please confirm, if true, that
there
were no changes that materially affected or were reasonably likely
to
materially affect your internal control over financial reporting.
This comment also applies to your Form 10-KSB for the fiscal year
ended December 31, 2004.  Additionally, ensure that your future
filings include language consistent with Item 308(c) of Regulation
S-
B.

*	*	*	*	*

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	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 information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all the facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequately
of
the disclosures they have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission 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 and 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.

	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 connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rule 461 regarding requesting
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

	If you have any questions regarding these comments, you may
contact Sara Kalin at (202) 551-3454.  If you need further
assistance, you may contact me at (202) 551-3730.

								Sincerely,

								Barbara C. Jacobs
								Assistant Director

cc:	Via Facsimile (212) 451-2999
	Mr. Elliot Lutzker, Esq.
	Robinson & Cole LLP
	Telephone: (212) 451-2900

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Ms. Angela Du
China Mobility Solutions, Inc.
October 11, 2005
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