SecProbe.io

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December 8, 2005

VIA TELEFAX (202) 772-9217
Zafar Hasan, Esq.
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

         Re:      AVVAA World Health Care Products, Inc.
                  Amendment No. 3 to Registration Statement on Form SB-2
                  File Number 333-124667

Dear Mr. Hasan:

We represent AVVAA World Health Care Products,  Inc.  ("AVVAA").  In response to
Mr. Oscar Young's verbal comments  regarding the above  referenced  filing,  the
following are the Company's responses:

Question 1

In the May 31, 2005 10-KSB in paragraph 8 (a) regarding controls and procedures,
you need to confirm  whether or not the Certifying  Officers  concluded that the
control  procedures  were effective at May 31, 2005. If so, please state how the
Officers came to such conclusion.

Additionally,  please  disclose  whether the error in  accounting  for the stock
options  resulted from a failure to properly  record,  process,  summarize,  and
communicate  the  options  or  whether  the  error  occurred  as a result of the
incorrect financial accounting for such options.

Answer:  The Certifying  Officers  determined  that the control  procedures were
effective  at May 31,  2005.  The Company is  satisfied  that  adequate  control
procedures  are  currently in place and no  additional  changes to the financial
statements are required.  During  preparation of the February 28, 2005 financial
statements,  it was  discovered  that the fair  value of certain  stock  options
granted to outside  consultants,  while  properly  disclosed in the notes to the
financial  statements,  had not  been  expensed  in the May 31,  2004  financial
statements,  as required by generally accepted accounting  principles  ("GAAP").
All  of  the  options  were  properly   recorded,   processed,   summarized  and
communicated to management. The error did not occur as a result of any breach of
disclosure controls, but rather, as a result of incorrect application of GAAP to
the accounting for the consultant stock options.

Section 8(a) of the May 31, 2005 10-KSB has been amended as follows:

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     "Our Chief Executive Officer and Chief Financial Officer  (collectively the
     "Certifying  Officers")  maintain  a  system  of  disclosure  controls  and
     procedures   that  is  designed  to  provide   reasonable   assurance  that
     information,  which is required to be  disclosed,  is recorded,  processed,
     summarized,  and  communicated  within the time  periods  specified  in the
     Commission's  rules and forms.  During preparation of the February 28, 2005
     financial  statements,  it was  discovered  that the fair  value of certain
     stock options granted to outside  consultants,  while properly disclosed in
     the notes to the financial statements, had not been expensed in the May 31,
     2004 financial  statements,  as required by generally  accepted  accounting
     principles ("GAAP"). All of the options were properly recorded,  processed,
     summarized and  communicated  to  management.  The error did not occur as a
     result of any breach of  disclosure  controls  but  rather,  as a result of
     incorrect  application  of  GAAP to the  accounting  for  consultant  stock
     options.  The  required  amended  financial  statements  were  filed in the
     amended Form 10-KSB for the year ended May 31, 2004.

     The Company's  system of disclosure  controls and procedures were augmented
     in September 2004,  through the Company  obtaining  accounting  advice from
     external  advisors  on  technical  GAAP  issues.  The  Certifying  Officers
     believe,  based on controls in place at May 31,  2005,  that the  Company's
     control procedures at May 31 2005 are effective.

     Changes in internal controls

     In July 2005,  additional  controls and procedures  were  implemented  with
     respect to stock  options  granted and common  shares issued as approved by
     the Company's Board of Directors.  A separate  control log is maintained by
     the   Company's   Administrative   Accounting   Assistant.   This   log  is
     independently  reviewed by the Company's  Controller  and Chief  Accounting
     Officer.  These  procedures  were  executed  in July 2005 and  carried  out
     retroactively to June 1, 2003. No additional errors were detected."

If you have any questions, please call me.

Very truly yours,

ANSLOW & JACLIN, LLP

BY:   /s/ Richard I. Anslow
      ---------------------
          RICHARD I. ANSLOW

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