SecProbe.io

August 20, 2008

 Mail Stop 4561  Mr. Wang Wen Yan Chief Financial Officer Sunrise Real Estate Group, Inc. Suite 701, No. 333, Zhaojiabang Road Shanghai, PRC 200032  Re: Item 4.02 Form 8-K  Filed August 18, 2008
File No. 000-32585
 Dear Mr. Wen Yan:   We have reviewed your Item 4.02 Form 8-K for compliance with the form requirements and have the following comments.  1. Please amend your report to include all of the information required by Item
4.02(a) of Form 8-K, including disclo sure of the following information:

• the date of the conclusion regarding the non-reliance;

• a brief description of the facts unde rlying the conclusion to the extent
known to you at the time of filing; and

• a statement of whether the audit committ ee, or the board of directors in the
absence of an audit committee, or aut horized officer or officers, discussed
with your independent accountant the matters disclosed in the filing
pursuant to this Item 4.02(a).
 2. Please include a signature on your amended Form 10-K.
  You should file an amendment in response to these comments on or before August 27, 2008.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision.  Since the company and its

Sunrise Real Estate Group, Inc.
August 20, 2008 Page 2  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.
  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
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities 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 filings or in response to our comments on your filings.     If you have any questions, please call me at (202) 551-3429.
         S i n c e r e l y ,

       K r i s t i  M a r r o n e         S t a f f  A c c o u n t a n t