SecProbe.io

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<FILENAME>filename1.txt
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Mail Stop 4561
      November 30, 2005

Mr. Clarence Lo
Chief Financial Officer
Sun New Media, Inc.
PO Box 297, 1142 South Diamond Bar Blvd
Diamond Bar, CA 91765

	RE:	Sun New Media, Inc.
		Form 8-K filed November 25, 2005
            	File No. 0-26347

Dear Mr. Lo:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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 be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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 filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call me at the telephone number
listed
at the end of this letter.

Form 8-K filed November 25, 2005

1. Amend the report to include all of the information required by
Item 304 of Regulation S-B.  Item 304(a)(1) of Regulation S-B
requires a statement whether during the registrant`s two most
recent
fiscal years and any subsequent interim period through the date of
resignation, declination or dismissal there were any disagreements
with the former accountant on any matter of accounting principles
or
practices, financial statement disclosure, or auditing scope or
procedure, which disagreement(s), if not resolved to the
satisfaction
of the former accountant, would have caused it to make reference
to
the subject matter of the disagreement(s) in connection with its
reports.  In the event of disagreement(s) and/or reportable
event(s),
provide the specific disclosures required by Item 304(a)(1)(iv)
and
(v) of Regulation S-B.

Exhibit 16

2. To the extent that you make changes to the Form 8-K to comply
with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountant stating whether the accountant agrees
with
the statements made in your revised Form 8-K.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed investment decision.  Since the company and its
management are in possession of all facts relating 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 filing;

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

* the company may not assert staff comments 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 our review of your filing or in
response to our comments on your filing.

	Please provide the supplemental information requested above
within five business days from the date of this letter.  The
supplemental information should be filed as correspondence on
EDGAR.

      Any questions regarding the above should be directed to me
at
(202) 551-3432.

								Sincerely,

								William H. Demarest
								Staff Accountant
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Mr. Clarence Lo
Sun New Media, Inc.
November 30, 2005
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