SecProbe.io

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                                                                    May 11, 2005

Larry  Spirgel,  Assistant Director
United States Securities and Exchange Commission
450 Fifth Street, N. W.
Washington, D. C.  20549

                  RE: Sunrise Real Estate Development Group, Inc.
                  Form 10-KSB for the fiscal year ended  December 31, 2004
                  Filed April 8, 2005

Dear  Mr.  Spirgel:

The following is in response to your inquiry of May 2, 2005 regarding the 10-KSB
filed by Sunrise Real Estate  Development  Group, Inc. for the fiscal year ended
December 31, 2004:

1.       Question:  It appears  that the acquiree  for  accounting  purposes had
         6,630,614  outstanding  shares as of December 27, 2003.  Please confirm
         that  6,000  shares  were  subsequently   issued.   (from  Consolidated
         Statement of Stockholder's Equity, page F-4)

         Answer:  We confirm that 6,000 shares were subsequently issued.

2.       Question: Please tell us why $2,000,000 was recorded as additional paid
         in  capital  for  the  recapitalization  of LRY.  Also  tell us why the
         $2,000,000 was reflected as a financing  activity un your consolidation
         statements   of  cash   flows.   (from   Consolidated   Statements   of
         Stockholder's Equity, page F-4)

         Answer: LRY was capitalized with the $2,000,000 in 2004, and therefore,
         the cash inflow was a financing  activity.  The equity was  recorded as
         additional  paid-  in-capital  as LRY  was  jointly  considered  as the
         accounting acquirer with CY-SRRE in the reverse merger.

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Sunrise Real Estate Development Group, Inc. Reply
Page  2

3.       Question: Please tell us how you concluded that CY-SRRE and LRY are the
         combined  accounting  acquirer  under  paragraph 17 and 18 of SFAS 141.
         (Note 1. Organization and Description of Business, page F-6)

         Answer:  CY-SRRE and LRY were  entities  under common  control and were
         combined as part of the recapitalization; thus there were two acquirers
         and they had a common shareholder, Ace Develop Properties Limited.

If you have any other  questions,  please let me know.  My  telephone  number in
Shanghai, China, is +86-21-64220505, and my FAX number is +86-21-64223009.

Sincerely,

Art Honanyan
Chief Financial Officer
Sunrise Real Estate Development Group, Inc.
Suite 1502
No. 333 Zhaojiabang Road
Shanghai, China PRC  200032

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