SecProbe.io

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<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
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                               Michael A. Littman
                                 Attorney at Law
                                7609 Ralston Road
                                Arvada, CO 80002
                                 (303) 422-8127
                               Fax (303) 431-1567

                                October 18, 2005

Sherri Bowen
Securities & Exchange Commission
450 Fifth Street NW
Washington, DC 20549

Re:      China Mobility Solutions, Inc.
         Comment Letter Dated July 11, 2005
         File No. 026559

Dear Ms. Bowen:

         In response to your comment  letter,  we have the  following  responses
which  correspond  to the  numbered  comments  in your  letter.  We have filed a
10KSB/A  addressing  the  comments  and a marked copy of the 10KSB/A is attached
hereto and page numbers in the comments refer to the 10KSB/A.

         1.  In response to  Comment #1,  the breakdown  of deferred revenue  of
$2.1  million  at  December  31,  2004 is as  follows:  - SMS -  $2,105,165  and
Education and Training - $6,533.  Following is the amended language at p. 11 and
Note 1, p. F-7.

         "The Company also carries  deferred  revenue of $2,105,165  for its SMS
business in China and $6,533 for its education and training business."

         2.  In response to Comment #2,  we have added in  Note 1 the  following
text  at p.  F-7.  "All  the  mobile  communication  service  is  provided  on a
subscription  basis.  All the  customers  have to pay in advance a deposit for a
one-year  service to be provided.  Revenue has been  allocated  over the service
period." No services are "bundled"  that could be  individually  broken out. The
accounting  treatment is in accordance  with SEC Staff  Accounting  Bulletin No.
101, "Revenue Recognition in Financial Statements."

<PAGE>

Sherri Bowen
Securities & Exchange Commission
October 18, 2005
Page 2

         3. In response to  Comment #3,  the  "Recent Accounting Pronouncements"
section has been amended in the 10-KSB/A at p. F-11 to add:

         "The  Company   completed  the   evaluation  of  EITF  00-21   'Revenue
Arrangements with Multiple Deliverables' in year 2004. The Company has concluded
the  implementation  of EITF  00-21  does not have any  impact on the  financial
position and results of operations of the Company.
         "The Company also completed the evaluation of FIN46  'Consolidation  of
Variable  Interest  Entities'  in year  2004.  The  Company  has  concluded  the
implementation  of FIN46 does not have any impact on the financial  position and
results of operations of the Company."

         4.  In response to Comment #4 (first bullet point):

         The Company  controls 51% ownership in Beijing  Quicknet.  49% has been
purchased  directly by the Company as disclosed  in Form 8-K dated  February 16,
2004 filed on February 17, 2004. The additional 2% ownership is held through the
Company,  Beijing ShiJi  RongChuang Tech, LTD., of which the sole shareholder is
Xin Wei,  the CEO of Beijing  Quicknet,  who is a Chinese  citizen and meets the
Chinese regulatory  requirements.  The 2% ownership interest in Beijing Quicknet
is optioned for $100,  by the Company  from Mr. Wei,  and the Company  holds the
proxy for voting all the shares of Beijing Quicknet and has the right to appoint
and elect the directors of Beijing Quicknet pursuant to a written agreement. The
2% will be transferred to the Company when the  applicable  Chinese  regulations
allow the transfer or there is another legal mechanism for such a transfer. This
arrangement  was included in the 8-K/A dated February 19, 2004 filed on February
25, 2004 and in the exhibit thereto. See Exhibits attached hereto.

         The  Company  has Xin Wei's  proxy to vote his 2% of shares  and so the
Company  will vote the 2% of Beijing  Quicknet  according to the interest of the
Company.  Including the  additional  2% equity  interest in control and with the
right to appoint and elect the Board,  it enabled  the Company to conclude  that
the Company has acquired,  for accounting purposes,  the additional 2% ownership
interest. (See Supplemental Exhibits 4.1 - 4.6.)

         FIN46  is not  applicable  in this  case  as  Beijing  Quicknet  is not
considered as a variable  interest  entity.  The  shareholding  arrangements are
solely for  adapting  to the  regulations  of China.  The Company has the direct
ability to make decisions about Beijing Quicknet  activities  through appointing
the entire board of  directors.  The  financials  of Beijing  Quicknet have been
included in the consolidated financial statements of the Company.

         (Second bullet point):

<PAGE>

Sherri Bowen
Securities & Exchange Commission
October 18, 2005
Page 3

         The Company still has not received the Chinese  regulatory  approval of
the 2% equity interest transfer.

         (Third bullet point):

         The Company  believes the Chinese  government will gradually loosen the
control  in   telecommunication   business   after   entering  the  World  Trade
Organization.  The Company is also actively  seeking  another  acceptable  legal
mechanism to speed up the transfer of the 2% ownership.

         (Fourth bullet point):

         The operations of Beijing  Quicknet is currently  managed by the CEO of
such Company,  Mr. Xin Wei, who reports almost daily to Angela Du, the Company's
President.  All accounting for the Beijing Quicknet is handled by accountants in
China and reviewed monthly by the Company's accountant.

         In response to the last  subcomment  under Comment #4, the amendment to
the Share Purchase  Agreement  (Exhibit 10.1a as filed in the 8-K dated February
24, 2004) defines the 49% and the 2% arrangement for $100 when approval is given
by PRC. This amendment also provides the voting of all shares by Xin Net and the
appointment     of     directors,      officers,     and     managers.      (See
sec.gov/archives/edgar/data/1082603/000107258804000040/ex1a.txt.)  The 8- K/A of
February 25, 2004  disclosed  that the other owners of Quicknet were Fang Hu and
Bo Yu. Xin Wei  acquired  the 2%  interest  in the Spring of 2004 to comply with
Chinese regulations.

         5.  In response to Comment #5, the data under section "A. By geographic
areas" for 2003 was incorrectly  entered during the  Edgarization of the 10-KSB.
The10-KSB/A,  as filed,  corrects  the errors at p. F-15.  The  amendment  is as
follows:

<TABLE>
<CAPTION>

                                                     China             Canada           Other             Total
<S>                                                 <C>                <C>              <C>             <C>
For the year ended December 31, 2003
Revenue from continuing operations                   $      -          $280,723         $     -         $  280,723
Operating profit (loss)                                (2,395)         (110,325)        (77,990)          (190,710)
Total assets                                        5,675,109           151,474         494,029          6,320,612
Depreciation                                                -             6,680             714              7,394
Interest income                                        15,049                12               5             15,066
Loss from discontinued operations                    (106,281)                -               -           (106,281)
Equity loss in undistributed earnings of
  investee company                                          -                 -         (66,076)           (66,076)

<PAGE>

Sherri Bowen
Securities & Exchange Commission
October 18, 2005
Page 4

Investment in equity method investee                        -                 -         253,524            253,524
</TABLE>

         6. In response to Comment #6, the Company was able to conclude that the
disclosure  controls and  procedures  were  effective at December 31, 2004 when,
during the course of the preparation of the financial  statements for the audit,
the Company did not find any significant  financial  discrepancies or disclosure
discrepancies from its internal statements or its quarterly statements.

         The  Company  did  not  have,  in  certain  areas,  documented  control
procedures for its subsidiary  Beijing Quicknet which  approximated those in the
C0S0 framework (which has become the model by default), in a manual. These areas
were  in  expenditure   approval  and  documentation  in  the  Beijing  Quicknet
subsidiary  and in the  recording  and tracking of  subscription  revenue in the
Beijing Quicknet subsidiary.  Management and its internal accountants made their
determination  of this  deficiency  after the first quarter of 2005 as they were
preparing  the  financial  statements  for review as a precaution  to ensure its
foreign operations were in compliance with all controls and procedures necessary
to have accurate financials.

         7. In response to Comment #7, the Company has not  determined  that any
inaccuracy in the financial statements  resulted,  merely than controls could be
improved for its foreign  subsidiary.  The Company has implemented the following
major changes in procedures set forth in its manual:

                  A.  Expenditure controls/approvals  and documentation by Board
Committee for the subsidiary in China, Beijing Quicknet; and

                  B.  Subscription accounting and tracking for its subsidiary in
China, Beijing Quicknet.

         All changes are expected to be fully implemented by year end 2005.

         The Company has provided the responses  above.  It does not appear,  in
reviewing the comment, that it is necessary to revise any of the text in Item 8A
in response to Comments #6 and #7.

         8.  In response  to  Comment #8,  the following  has been  added to the
notes to the financial statements under the "Section: Legal Proceedings":

<PAGE>

Sherri Bowen
Securities & Exchange Commission
October 18, 2005
Page 5

         On Feb.7, 2005, China Mobility Solutions, Inc. was sued by Sino-I Tech-
nology Limited for $88,270 for breach of warranty and a claim under a guarantee.
The Company is vigorously defending the suit.  Discovery is proceeding.

         The "Tandy" letter was filed on correspondence on September 13, 2005.

         We hope this response together with the 10-KSB/A (as attached) filed is
an adequate response upon your review.

                                           Sincerely,

                                           /s/ Michael A. Littman
                                           Michael A. Littman

MAL:jb
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