SecProbe.io

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Mail Stop 6010	October 26, 2005

Zhilin Li
President and Chief Executive Officer
12890 Hilltop Road
Argyle, Texas 76226

      RE: 	TS Electronics, Inc.
      	Form SB-2
      	Filed October 20, 2005

Dear Ms. Li:

      This is to advise you that we are not conducting a full
review
of the Form SB-2 filed by TS Electronics, Inc. (the "Company") on
October 20, 2005.  However, we will be monitoring the filing for
resolution of issues relating to the registration of shares and
required signatures.

      With regard to the signatures, Form SB-2 includes
requirements
for signatures, including the signature of the company`s chief
accounting officer.  Please see the instructions to signatures on
Form SB-2.  With regard to the registration of shares, we note
that
the company is registering significantly more shares than are
listed
on the selling securityholder table.  We also note that Mr. Evans
currently owns 703, 836 shares, is listed as having zero shares
after
the offering but is only listed as selling 9275 shares.  Please
review these figures and advise us as to the discrepancy between
Mr.
Evans shares before and after the offering.

      In addition, it appears that you have not properly allocated
shares that are in the secondary offering as distinct from primary
offerings.  You must revise the registration statement to allocate
a
specific number of shares to the secondary offering.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:
?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

?	the company may not assert this action 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      As appropriate, please amend your filing 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.

      Any comments or questions may be directed to Zafar Hasan at
(202) 551-3653 or to me at (202) 551-3715.

      Sincerely,

								Jeffrey Riedler
								Assistant Director

CC:  	Charles Law
	King and Wood LLP
	Palo Alto, CA 94304
	F: 650-494-1387
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