SecProbe.io

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                            GFR PHARMACEUTICALS, INC.
                            SUITE11405 - 201A STREET
                      MAPLE RIDGE, BRITISH COLUMBIA V2X 0Y3

                                                              September 29, 2005

VIA EDGAR

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-0406
Attention: Linda Cvrkel, Branch Chief

RE:      GFR PHARMACEUTICALS, INC.
         FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2004
         COMMISSION FILE #: 0-27959

Ladies and Gentlemen;

         We have  received  your  comments to our Form 10-KSB for the year ended
December  31,  2005 and thank for your  review to assist and enhance the overall
disclosure in our Exchange Act filings.  We  supplementally  responds to all the
your comments as follows:

General
-------

1.       Please include the  information  required by Item 406 of Regulation S-B
         regarding a code of ethics. See Item 9 of Form 10-KSB.

RESPONSE: As a student member of the Society of Certified General Accountants of
British Columbia all my work is guided by the societies code of ethics and rules
of conduct.  I will revise Item 9 to reflect  that this code of ethics and rules
of conduct are followed  when  producing  statements  for the SEC and attach the
document to the letter. I am attaching a copy of this code for submission.

<PAGE>

Markets
-------

2. We note one customer  accounted  for 49% of your sales  during  2004.  Please
identify this customer. If you have a written agreement with this customer, file
the agreement  pursuant to Item  601(b)(10)  of Regualtion  S-B, and discuss the
agreement's material terms in the body of the filing.

RESPONSE: We will identify the customer,  Prairie Naturals,  however there is no
written agreement between the two companies as of Dec 31, 2004.

3. You mention prinicipal  customers on pages 5, 8, and F-14. Based on the large
percentage of revenues  attributable to the customers  discussed on these pages,
it appears the  disclosure on all three pages might refer to the same  customer.
However, the percentages of revenues  attributable to the principal customer are
inconsisten.  Page 5  states  the  customer  is  responsible  for 49% and 58% of
revenues  during 2004 and 2004,  page 8 states they are  responsible for 50% and
40%,  and  page  F-14  states  they  are  responsible  for 37% and  50%.  If the
disclosure on all three pages refers to the same customer,  please reconcile the
percentages of revenue.

RESPONSE:  We  mentioned  the sales  percentages  for Prairie  Naturals  for the
periods 2003 and 2004 on pages 5, 8, and F-14 but the  percentage on each is not
identical.  The correct  percentages are calculated below and We will revise the
report accordingly.

GFR Pharmaceutical Inc.
Major Customer Sales Percentage Calculation

                                            2004                    2003

GFR Pharma                              6,323,574.10            6,026,131.73
GFR Health                              3,100,272.95            2,319,846.23
Intercompany                           (1,800,188.00)          (1,342,937.00)
                                       -------------           -------------
Total Consolidated Sales                7,623,659.05            7,003,040.96
                                        ============            ============

Prairie Natural Sales                   3,063,322.30            2,963,140.60
GFR Pharma                                 36,000.75              170,282.50
                                        ------------            ------------
GFR Health                              3,099,323.05            3,133,423.10
                                        ============            ============

Total Consolidated Sales %                      41%                     45%

Item 2.  Description of Property
--------------------------------

4. Please file the lease  agreements for both your  operations and the warehouse
space. See Item 601(b)(10)(i)(D) of Regulation S-B.

RESPONSE: We will file these agreements as exhibits.

<PAGE>

Item 6. Management's Discussion and Analysis
--------------------------------------------

Results of Operations
---------------------

5. Please  disclose  the reason for the  $344,000  increase in foreign  currency
transaction gains in 2004 and explain to us.

RESPONSE: In years prior to 2004 the translation  adjstments from Canadian to US
Dollars were reported on the balance sheet. In 2004 we have found that they were
erronously expensed. We will correct this error and amend the filing.

6.  Please  disclose  the  reason why your  effective  tax rate  decreased  from
approximately  48% in 2003 to  approximately  7% in  2004.  If  decrease  in the
effective tax rate is a result of several factors, please quantify the amount of
change due to each factor.

RESPONSE: We will revise to disclose that for 2004 were benefited from prior tax
loss carryforwards.

Critical Accounting Policies
----------------------------

7. Please revise your disclosure to discuss your critical accounting policies in
this section of the filing since no accounting  policies appear to be identified
as  critical  in the  notes  to your  financial  statements..  Please  refer  to
Financial Reporting Release 72 for guidance on disclosure of critical accounting
estimates.

RESPONSE:  We will  revise our  disclosure  to include our  critical  accounting
policies in the section of the filing.

Item 9. Directors,  Executive Offices, Promoters and Control Persons; Compliance
--------------------------------------------------------------------------------
with Section 16(a) of the Exchange Act
--------------------------------------

8. Please  provide  disclosure  in Item 9 and on the  signature  page that would
indicate all those  persons who serve in the capacity of director in addition to
the other capacities in which they might serve. From the disclosure provided, it
is unclear  whether a majority of the Board has signed the filing.  If they have
not,  please  provide  the  signatures  of a majority of the Board in an amended
10-KSB including all of the 10-KSB disclosure.

RESPONSE:  Of the three persons mentioned in item 9 only Richard Pierce and Rose
Marie Pierce are Directors of GFR Pharmaceuticals,  Inc.. In addition to being a
director  Richard  Pierce is also the CEO. Marc Casavant is the CFO. We have two
board menbers and a CFO. All three have signed the disclosure.

Item 12. Certain Relationships and Related Transactions
-------------------------------------------------------

9. Please state the name of each related party  discussed in this  section,  and
explain how they are related to the company.  Also,  please file as exhibits any
written   agreements   underlying   the   transactions   discussed.   See   Item
601(b)(10)(i)(A) of Regulation S-B.

<PAGE>

RESPONSE: We will revise disclosure such that all Major shareholders and related
parties have been named. We will also revise  disclosure for a correction in the
years that royalty payments were made.

Consolidated Financial Statements
---------------------------------

Notes to Consolidated Financial Statements
------------------------------------------

10. Due to the significant foreign currency transaction gains in 2004 it appears
that  information  about  geographic  areas  under  paragraph  38 of SFAS 131 is
required. Please tell us why these disclosures were not provided in your filing.

RESPONSE:  We have made a  correction  to the foreign  currency as  discussed in
response to comment 5. We do not have segment information to disclose.

Signature Page
--------------

11. We note thr filing does not include the  signature  of your  controllong  or
principal accounting officer.  Please include the signature in your amended Form
10-KSB.  If Marc  casavant,  the CFO, also serves as the controller or principal
accounting  officer,  his signature  should be captioned as such in your amended
filing. See General Instruction C.2 to Form 10-KSB.

RESPONSE:  We have revised the signature of Marc Casavant to include the caption
of principal accounting officer.

         With respect to the above  comments and responses the  undersigned,  on
behalf of GFR Pharmaceuticals, Inc. (the "Company") acknowledges the following:

1.       The  Company  is  responsible  for the  adequacy  and  accuracy  of the
         disclosure in the filings;

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

3.       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.

                                Respectfully Submitted,

                                /s/ Richard Pierce
                                Richard Pierce,
                                President and C.E.O.

<PAGE>

Proposed Amended 10-KSB for 12/31/04

                     U.S. Securities and Exchange Commission

                              Washington, Dc 20549

                                  FORM 10-KSB/A

           [ X ] ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(D) OF THE
                         SECURITIES EXCHANGE ACT OF 1934

                   For the fiscal year ended December 31, 2004
                                             -----------------

                        Commission file number 000-27959

                            GFR Pharmaceuticals, Inc.
                            -------------------------
                 (Name of small business issuer in its charter)

             Nevada                                      77-0517964
---------------------------------           ------------------------------------
  (State or other jurisdiction              (I.R.S. Employer Identification No.)
of incorporation or organization)

        Suite 11405 - 201A Street, Maple Ridge, British Columbia V2X 0Y3
             (Address of principal executive office) Zip/Postal Code

         Issuer's telephone number: (604) 460-8440

Securities registered pursuant to Section 12(b) of the Act: None
                                                            ----

Securities registered pursuant to Section 12(g) of the Act:

                                  Common Stock
                                (Title of Class)

         Check whether the issuer (1) has filed all reports required to be filed
by Section 13 or 15(d) of the  Exchange  Act during the  preceding 12 months (or
for such shorter  period that the registrant was required to file such reports),
and (2) has been subject to such filing requirements for the past 90 days. Yes (
X ) NO ( ).

         Check here if there is no disclosure  of delinquent  filers in response
to Item 405 of Regulation S-B contained in this form, and no disclosure  will be
contained,  to the  best of  registrant's  knowledge,  in  definitive  proxy  or
information  statements  incorporated  by reference in Part III of this Form 10-
KSB or any amendment to this Form 10-KSB. ( X )

         Issuer's revenues for its most recent fiscal year, were $5,859,763 .
                                                                 -----------

                                        1

<PAGE>

         Issuer's Common Shares  outstanding at December 31, 2004 was 1,079,940.
The  aggregate  market  value of voting and  non-voting  common  equity  held by
non-affiliates  as of April 5, 2005 was $127,485,  computed based on the average
bid and asked price of such common equity as of April 5, 2005.

         Except for the historical information contained herein, the matters set
forth in this Form 10- KSB are forward looking  statements within the meaning of
the "Safe Harbor" provision of the Private  Securities  Litigation Reform Act of
1995.  These  forward-looking  statements are subject to risk and  uncertainties
that may cause  actual  results  to  differ  materially.  These  forward-looking
statements  speak  only  as of the  date  hereof  and  Laredo  Investment  Corp.
disclaims any intent or obligation to update these forward-looking statements.

Documents Incorporated by Reference:  Certain exhibits

                                        2

<PAGE>

ITEM 1.           DESCRIPTION OF BUSINESS.

Business Development

GFR  Pharmaceuticals,  Inc.  (Formerly Laredo Investment Corp.) was incorporated
under the laws of the State of Nevada on December 18, 1996. GFR Pharmaceuticals,
Inc. ceased all operating activities during the period from December 18, 1996 to
July 9, 1999 and was considered dormant.  On July 9, 1999, GFR  Pharmaceuticals,
Inc.  obtained a certificate  of renewal from the State of Nevada.  From July 9,
1999 to January 21,  2000,  GFR  Pharmaceuticals,  Inc.  was in the  development
stage.

On January 21, 2000, the Company entered into an Acquisition  Agreement with GFR
Pharm, Ltd. (Formerly GFR Nutritionals,  Ltd.), a British Columbia  corporation,
(GFR), Richard Pierce and Lucretia  Schanfarber (the GFR Majority  Shareholders)
to acquire their shares representing 100% of the outstanding common stock of GFR
in exchange for  19,000,000  newly issued shares of Laredo's  restricted  common
stock.  The  transaction  was  recorded  as  a  reverse  acquisition.   GFR  was
incorporated in March 1997 as Helm  Developments  Ltd. In June 1998, the Company
formally  changed its name to GFR  Nutritionals  Ltd.  GFR was 100% owned by the
President and CEO,  Richard Pierce from inception until January 17, 2000, when a
10% interest was acquired by Lucretia Schanfarber.  Business operations began in
October  1998  after   acquiring   manufacturing   equipment  and  arranging  to
manufacture nutritional supplements under a private label contract.

On June 21,  2000,  the  Company  entered  into an  Acquisition  Agreement  with
Nutritionals (USA) Direct.Com, a Washington corporation,  (NDC), to acquire 100%
of the outstanding  common stock of NDC in exchange for $1,000.  The transaction
has been recorded as a purchase.  NDC operations were wound down in October 2002
and the company became dormant.

On November 1, 2000,  GFR  Pharmaceuticals,  Inc.  entered  into an  Acquisition
Agreement with R & L Health,  Inc., a British  Columbia  corporation,  (R&L), to
acquire 100% of the outstanding  common stock of R&L in exchange for $0.01.  The
transaction was recorded as a purchase.

On April 5, 2004, GFR Nutritionals,  Ltd. and R&L Health,  Inc. changed its name
to GFR Pharma, Inc. and GFR Health, Inc., respectively.

On  August  9,  2004,   Laredo   Investment  Corp.   changed  its  name  to  GFR
Pharmaceuticals, Inc.

Narrative Description of the Business

GFR Pharma, Ltd. (Formerly GFR Nutritionals Ltd.), GFR  Pharmaceuticals,  Inc.'s
wholly owned  subsidiary is an established  manufacturer of quality  nutritional
supplement products. GFR Pharma, Ltd. (Formerly GFR Nutritionals Ltd.), operates
a full service manufacturing facility that produces natural-source  nutritional,
vitamin,  mineral,  herbal  sports  nutrition  products  and  over  the  counter
pharmaceutical products which are sold on a private label basis to wholesale and
retail   clients.   GFR  Health,   Inc.   (Formerly   R&L  Health   Inc.),   GFR
Pharmaceuticals,  Inc.'s wholesale division markets products manufactured by GFR
to mass market retailers.

                                        3

<PAGE>

Nutritional  supplements  are being  increasingly  recognized by the medical and
scientific communities as an integral component of a healthy lifestyle.  Much of
the growth in this industry is driven by six key factors:

         o        Positive  publicity - For several years,  medical journals and