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CORRESP
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      China Mobility Form Corresp 12/23/2005

    December
      23, 2005

    Ms.
      Barbara C. Jacobs

    Assistant
      Director

    Division
      of Corporation Finance

    United
      States Securities and Exchange Commission

    100
      F
      Street, NE

    Washington,
      DC 20549

    Re: China
      Mobility Solutions, Inc.

    Amendment
      No. 1 to Registration Statement on Form SB-2 Filed
      November 14, 2005

    File
      No. 333-128323

    Form
      10-MB 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

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

    File
      No.
      0-26559

    Dear
      Ms.
      Jacobs:

    In
      response with the above-referenced matter and on behalf of our client China
      Mobility Solutions, Inc. (the “Company”), we filed a draft response to your
      letter to Ms. Angela Du, dated December 12, 2005. We address your comments
      in
      the order in which they appear in your letter. Due to the complexity in the
      accounting treatments, we want to seek your agreement in principle on the
      accounting treatments prior to amending the consolidated financial statements
      for the quarter ended September 30, 2005.

    Registration
      Statement on Form SB-2 Selling
      Stockholders, page 40

              1.

              We
                will revise this section to provide the material terms of the agreement
                and the Placement Agent Agreement will be filed as an exhibit in
                the next
                amendment.

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    Legal
      Opinion

            2.

              The
                opinion letter will be revised accordingly.

    Quicknet
      Transactions

              3.

              Note
                3 has been amended to reflect that Quicknet was a 51% owned subsidiary
                company and Quicknet has been removed from Note 2 as a wholly-owned
                subsidiary.

               4.

              The
                Company recorded goodwill of $846,782 on the acquisition of the initial
                49% interest in Quicknet. Please refer to the table in Note 3 of
                the
                consolidated financial statements for the year ended December 31,
                2004
                showing the value assigned to assets and liabilities
                acquired.

      5.
The
      Company has used consolidation accounting since June 30, 2004 to account for
      the
      51% investment in Quicknet from June 30, 2004. The minority interest in the
      statement of operations in each period represents the minority share of the
      49%
      post-acquisition profit or loss of the period. The Company has used
      consolidation accounting to record 100% of the post-acquisition profit or loss
      of Quicknet after the acquisition of the additional 49% equity interest in
      Quicknet.

              6.

              The
                transaction was completed on September 30, 2005 when the Company
                paid
                $2,000,000.

              7.

              Quicknet
                is subject to consolidation as the Company has the direct ability
                through
                voting rights to make decisions about Quicknet’s activities.

    There
      are
      no restrictions placed upon the authority of the Board to control the activities
      of Quicknet.

      The proxy granted is unconditional, irrevocable and without time limit as per
      our legal opinion attached hereto..

    The
      sellers understood that the proxy grant agreement was one of the terms of the
      deal and was required address the restrictions on foreign ownership of
      telecommunication companies in China. The sellers did not receive any
      compensation of any type for entering into the proxy grant agreement.

    The
      proxy
      agreement within the amendment to the Share Purchase Agreement is legal under
      the Chinese Law. Please refer to the attached legal opinion letter.

    All
      the
      Board decisions do not have to be ratified by Quicknet before
      approval.

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    8. The
      pro
      forma information is included in Note 3 of the notes to the consolidated
      financial statements. However, the information was omitted by mistake during
      the
      preparation of the 10-KSB. The amended 10-KSB has incorporated the pro forma
      information.

    Note
      1
      to the Financial Statements-Revenue Recognition

              9.

              Currently,
                all the service contracts are under the term of one-year service
                period.
                Revenue is recognized in the statement of operations evenly over
                the
                twelve-month service period.

    When
      the
      service arrangements exceed a one year timeframe, the Company will recognize
      the
      revenue evenly over the period the services are provided.

    Form
      10-QSB for the quarter ended September_30, 2005

    Unit
      Issuance

              10.

              The
                convertible debenture itself is a conventional convertible debt
                instrument. The holder can exercise the option to convert the debenture
                into equity shares within the specified time period at a specified
                price
                or hold the debenture to maturity for repayment of principal and
                interest.
                There is no anti-dilution or other provisions in the agreement that
                can
                result in the conversion ratio not being
                fixed.

    The
      Series “C” and “D” warrants included in each Unit sold do not have any effect on
      the redemption or early settlement of the convertible debentures. Both warrants
      are separated from the convertible debentures and can be exercised within
      specified periods at specified prices. If the related shares cannot be
      registered, the Company is only obligated to issue unregistered shares to the
      warrants holders when the warrants are exercised. Thus DIG B-16 does not apply
      to our case.

                                     11.

              The
                Series “C” and “D” warrants issued through the Units sold are considered
                as equity instruments. These warrants are separated from the convertible
                debentures and are not affected by any of the redemption or early
                settlement feature of the convertible debentures. The exercisability
                of
                the warrants is not contingently depending on the terms of the convertible
                debentures. The warrants can be exercised within their own specified
                periods at specified prices. If the related shares cannot be registered,
                the Company is only obligated to issue unregistered shares to the
                warrants
                holders when the warrants are exercised without any penalty. There
                is no
                penalty payable in cash by the Company for these Series “C” and “D”
                warrants if the Company fails to register the shares. The Company
                also has
                enough authorized share capital to cover all the potential shares
                to be
                issued.

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    The
      Series “C” and “D” warrants are thus classified as equity instruments. The fair
      value of the warrants are $24,286 ($0.34 * 71,429) and $27,143 ($0.38 * 71,429)
      each, respectively, as determined by using the Black-Scholes Model. The total
      fair value of the warrants $6,891,486 ($24,286 * 134 + $27,143 * 134) should
      be
      recorded as an expense in the statement of operation and a separate line in
      the
      equity section of the balance sheet as the amount involved is regarded as a
      cost
      of issuance of the convertible debenture. Revaluation has to be done on a
      periodic basis to update the fair value of the warrants. The periodic difference
      will be charged to the statement of operation as expenses or expenses recovery
      and adjustment to the fair value of the warrants in the equity section of the
      balance sheet.

    The
      consolidated financial statements for the quarter ended September 30, 2005
      will
      be amended accordingly.

    12. The
      registration rights and liquidation damages only apply to the convertible
      debentures and not the Series “C” and “D” warrants. In case the Company fails to
      register the shares for any reasons, the Company is only obligated to issued
      unregistered shares to the warrant holders when the warrants are exercised
      at
      the specified prices and within the specified time period. Thus, paragraph
      16 of
      EITF 00-19 does not apply to our warrants and the warrants are not deemed a
      liability under paragraph 6 of SFAS 133 as the warrants can be separately
      identified and measured.

    Controls
      and Procedures, page 18

            13.

              Management’s
                effectiveness determination was made with respect to the Company’s
                disclosure controls and procedures as that term defined under the
                Act.

    Our
      next
      periodic filing will refer to the definition included in Rule
      13a-15e.

            14.

              The
                Company will be compliance with this requirement in the amendment
                documents.

    If
      you
      wish to discuss the forgoing, please call Moen and Company at (604) 662-8899
      or
      Ms. Angela Du, President of the Company at (604) 632-9638.

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    Legal
      Opinion

    Ms.
      Barbara C. Jacobs

    Assistant
      Director

    Division
      of Corporation Finance

    United
      States Securities and Exchange Commission

    100
      F
      Street, NE

    Washington,
      DC 20549

    This
      Legal Opinion has been issued by BEIJING ZE PU LV SHI SHI WU SUO on December
      16,
      2005 in Beijing. Our firm confirmed the following:

    Under
      Chinese Law, a proxy grant can be unconditional, irrevocable and without time
      limit as long as all parties involved agree to it.

    Company
      Stamp

    Signature
      of the Lawyer

    Date:
      December 16, 2005.

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