SecProbe.io

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                  Letterhead of Schwartz Levitsky Feldman llp

By Facsimile to (202) - 942-9531 and EDGAR filing

February 18, 2005

United States Securities and Exchange Commission ("SEC")
450 Fifth Street, N.W
Washington, DC 20549
Unites States of America.

Attention: Ms. Meagan Caldwell
------------------------------

Dear Ms. Caldwell:

Re:     Medina Coffee, Inc. ("MCI")
        Registration on Form SB-2 filed January 21, 2005
        File No. 333-122209

We are the independent registered Public Accountants for Medina Coffee, Inc. our
client has forwarded a copy of your comment letter dated February 11, 2005 to us
and has directed our attention to item # 34 of your letter. You referred to your
Staff's  interpretation of Article 2 to Regulation SX which is to require " that
the audit  report on the  financial  statement  of a domestic  registrant  to be
rendered ordinarily by an auditor licensed in the US".

We subsequently contacted you to clarify the above comment as it pertains to our
client and to seek the  appropriate  guidance.  You  suggested  that we submit a
letter on this issue separate from MCI's formal  response letter to address this
matter.

Schwartz  Levitsky  Feldman LLP is one of the major  National firms of Chartered
Accountants in Canada with offices in various Provinces. Furthermore, we are the
Canadian member of HLB International, an affiliation of accounting firms in over
100  countries,  represented by more than 1,430 partners and 9,900 staff in over
400 offices.  We have a special division in our office that deals primarily with
US  filers  (registrants).  This  division  is  comprised  of  members  who  are
knowledgeable  in both  US GAAP  and US GAAS  and the  standards  of the  PCAOB.
Included in this division are several US CPA's.

<PAGE>

                                       2

In addition we have qualified  Chinese speaking staff in this division,  who are
both  familiar  with the  Chinese  business  environment  and  culture,  Chinese
accounting  systems Chinese GAAP and GAAS in addition to US GAAS. The members of
this  division  are updated on a weekly  basis on  developments  in  accounting,
auditing and SEC matters  through various  subscription  services in both the US
and Canada.  In addition,  members  attend  relevant live training  courses on a
regular basis.  We also became  registered  with the Public  Company  Accounting
Oversight Board ("PCAOB") on November 5, 2003

Since 1996,  we have acted as the auditors of numerous  Canadian  companies  who
have sought and are listed on various US exchanges both through the SB-2 and the
reverse merger process.  As a result of our HLB  affiliation,  we are approached
quite often by foreign  clients who are desirous of becoming  registrants in the
US either  through a reverse merger with a US listed shell company or through an
S-1, SB-2 or an F-1 filing.

In the  case of MCI,  the  independent  auditor  of  their  Chinese  subsidiary,
Shenzhen BAK Battery Co. Ltd.  (SBAK) and its parent  company BAK  International
Limited  ("BAKI"),  is a member  of the HLB  international  affiliation  who are
registered  with the PCAOB.  Due to our  experience  and  expertise  in auditing
foreign  companies  listed in the US,  our  knowledge  in US GAAP and GAAS,  the
standards of the PCAOB and the unique  challenges  which this presents,  we were
approached  by  BAKI,  SBAK  and our HLB  affiliate  to be the  auditors  of the
Company.  In this specific filing,  an additional  reason for selecting our firm
was that the Chinese speaking staff members in our public audit group both speak
and write English at a high level, a skill, which the Chinese member firm of HLB
International did not have.

The staff is also advised that in addition to our HLB affiliates' staff, we sent
our staff to China to both  supervise and help conduct the Audit at the client's
premises,  in  accordance  with the  standards  of the  PCAOB  and US  GAAS.  In
addition,  one of our  Partners  traveled  to China  and  visited  the  client's
premises  and met with both their CFO and CEO. The audit was also subject to our
firm's standard quality control reviews and procedures.

The  operations  of the company and the vast majority of its assets are situated
in China, even though MCI is the legal acquirer.  Under these circumstances,  we
believe  that the fact that MCI is a Nevada  corporation  should not be the sole
reason for  requiring  that the  auditor be  resident  and  licensed  in the US.
Furthermore  as the  legal  registrant  does not  have  significant  assets  and
liabilities,  and the  operations,  assets and  liabilities of BAKI and SBAK are
almost  entirely in China,  we believe  that the foreign  private  issuer  rules
should apply, so far as it pertains to the financial statements being audited by
a "registered foreign accountant" in good standing, as well as our connection to
China  through our HLB  affiliation.  We would also draw your  attention  to the
attached letter from the staff dated November 8, 1996 which effectively provided
us with clearance to perform US audits of foreign  entities  included in filings
with the SEC.

<PAGE>

                                       3

In  view  of  the  foregoing  and  as  Article  2 of  Regulation  S-X  does  not
specifically  preclude  similarly  situated audit firms from being  appointed as
auditor, and based on our belief that we are adequately qualified to conduct the
audit of MCI, we feel that we are in compliance with this Article.

We attach hereto  pertinent  documentation ( updated ) which we have provided in
previous submissions to both the SEC and NASDAQ to support our credentials.

We trust that the foregoing  adequately  addreses comment # 34 of your letter to
our client with respect to the above-mentioned Registration.  Should you require
any further information or clarification, please contact us.

Yours very truly,

SCHWARTZ LEVITSKY FELDMAN LLP

 /s/ Schwartz Levitsky Feldman LLP

GG/ch

Enclosures

<PAGE>
<TABLE>
<CAPTION>

                            SCHWARTZ LEVITSKY FELDMAN
                   PRESENT AND FORMER US LISTED AUDIT CLIENTS
                                January 31, 2005

                                          Stock Symbol   Listing               Status
------------------------------------------------------   -----------------     --------------
<S>                                                      <C>                   <C>
AlphaRx, Inc.                             ALRX.OB        OTC BB                Current
Banyan Corporation                        BANY.OB        OTC BB                just Appointed
China Automotive Systems Inc.             CAAS           Nasdaq SC             Current
First National Power Corporation          FNPR.OB        OTC BB                Just Appointed
IJJ Corporation                           IJJP.OB        OTC BB                Current
Maxus Technology Corporation              MXUS.OB        OTC BB                Current
Med-Emerg International Inc.              MDER.OB        OTC BB                Current
Perfisans Holdings, Inc.                  PFNH.OB        OTC BB                Current
Thinkpath Inc.                            THTHF.OB       OTC BB                Current
UCS Financial Inc.
Yukon Gold Corporation, Inc.              YGDC.OB        OTC BB                Current
China Bak Battery, Inc.                   CBBT.OB        OTC BB                Current
Dectron Internationale Inc                DELT           Nasdaq SC             Current
Medical International Technology Inc.     MDIR.OB        OTC. BB               Current
Curtis International Ltd.                 CURT.OB        Previously OTC BB     Now private
D.G. Jewellery of Canada                  DGJLQ.PK       PN K                  Bankrupt
Intercorp Excelle Corp.                   RENE.PK        Previoulsy PNK        Now private
Rosedale Decorative Products Ltd.         ROSD.PK        PN K                  Former client
Symons International Group                SIGC.PK        PN K                  Bankrupt
The Widecom Group Inc.                    WIDE.PK        PNK                   Bankrupt
Bank Engine Technologies Inc.             BKET.OB        OBB                   Former client
Homelife Inc.                             HMLF.OB        OTC.BB                Former client
Technical Ventures Inc.                   TEVT.PK        PNK                   Former client
Cosmo Communications Corp.                CSMO.PK        PN K                  Former client
Paradigm Advanced Technology              PRAVE.PK       PNK                   Former client
Zeolite Exploration Company               ZEOX.OB        OTC.BB                Former client
</TABLE>

<PAGE>

PCAOB                                                        1666 K Street, N.W.
Public Company Accounting Oversight Board                   Washington; DC 20006
                                                       Telephone: (202) 207-9100
                                                       Facsimile: (202) 862-8430
                                                                 www.pcaobus.org

                                November 5, 2003

Via Facsimile (416) 785-5663
And first Class Mail
--------------------

Mr. Gerald Goldberg
Partner
Schwartz Levitsky Feldman LLP
1167 Caledonia Road
Toronto, Ontario M6A 2X1
Canada

         Re: Registration Application of Schwartz Levitsky Feldman LLP

Dear Mr. Goldberg:

     This letter is to inform you that the Public Company  Accounting  Oversight
Board (the "Board") approved your application for registration with the Board on
November  5, 2003.  Please  note that the  Registration  staff  will  notify you
separately of its  determinations  with respect to any requests for confidential
treatment contained in your application.

                                   Sincerely,

                                    /s/ Patricia J. Thompson

                                   Patricia J. Thompson
                                   Deputy Director, Registration and Inspections

<PAGE>

Chartered                                                           APPENDIX III
Accountants
of Ontario

Mr. Kai Chang, CA
Schwartz Levitsky Feldman LLP
1167 Caledonia Road
Toronto ON M6A 2X1

Dear Mr. Chang:

RE: PRACTICE INSPECTION #R010466

The practice inspection committee has reviewed the report on the reinspection of
your office in conjunction with any additional comments supplied by you.

The committee has adopted the  inspector's  report and has  determined  that the
committee requires no further action at this time. Therefore, in accordance with
the normal  inspection cycle, your office will be subject to inspection again in
approximately three to five years, during the next cycle of inspections.

Subsequent to the interim  billing  previously  sent to you, we are enclosing an
invoice  for the balance of the time spent in respect of your  reinspection.  If
changes have been made to your report or the points for discussion subsequent to
forwarding  the initial copies to you,  additional  copies are attached for your
information. The changes are marked thereon.

Should you have any questions  concerning the report or the inspection  process,
please contact me.

Yours truly,

 /s/ Grant F. Dickson

Grant F. Dickson, FCA
Director of Practice Inspection

Encl.

               The institute of Chartered Accountants of Ontario,
                     69 Bloor Street East, Toronto, M4W 1E3
Phone:(416) 962-1841; Toll free:1-800-387-0735; Fax:Confidential (416) 962-2315
             Email: pracinsp(C)icao.on.ca; Website: www.icao.on.ca
<PAGE>

Chartered                                                            APPENDIX II
Accountants
of Ontario

PRIVATE AND CONFIDENTIAL

April 24, 1998

Mr. Sheldon B. Derrick, CA
Schwartz Levitsly Feldman
1167 Caledonia Road
TORONTO M6A 2X1

Dear Mr. Derrick:

We have been  notified  by NASDAQ  that your firm  audits one or more  companies
listed  on  NASDAQ.

In August 1997,  NASDAQ  introduced  new  qualification  requirements  requiring
auditors of Canadian  companies  listed on the exchange to undergo a peer review
comparable  to the AICPA  standards.  The  Canadian  provincial  institutes  and
representatives  of  some  of the  firms  involved  have  worked  with  NASDAQ's
representatives to obtain general acceptance of the Canadian inspection programs
as being comparable, and therefore avoiding additional reviews.

An Agreement was reached with NASDAQ on April 7, 1998. Under this agreement, the
Canadian inspection programs have been accepted as being comparable,  and NASDAQ
is requesting confirmation of the firms' participation in the programs,  through
notification of the date of the last inspection  (practice  review) of the firm.
In   Ontario,   the   practice   inspection   program   is   subject  to  strict
confidentiality,  and as a result,  we are requesting  your permission to notify
NASDAQ,  now  and in the  future,  of the  date  of  the  most  recent  practice
inspection. To facilitate this permission, please sign a copy of this letter and
return it to us in the enclosed envelope by no later than May 6, 1998.

For your information, the agreement with NASDAQ also includes a requirement that
"the institute  notify NASDAQ when a professional  conduct  committee has laid a
charge, emanating from a practice inspection referral on an audit-related issue,
before the institute's discipline committee". Public notification is permissible
at this  point in the  discipline  process,  and  therefore,  this is  simply an
advance request by NASDAQ to be included in such notification.

Yours truly,

 /s/ Grant F. Dickson

GRANT F. DICKSON, FCA
DIRECTOR OF PRACTICE INSPECTION

Encl.

       PERMISSION TO NOTIFY NASDAQ OF DATE OF MOST RECENT PRACTICE REVIEW

On behalf of the above named office of the above named firm, I hereby  authorize
the Institute of Chartered  Accountants  of Ontario to notify NASDAQ of the date
of the most recent practice  inspection.  This  authorization  is effective both
currently and continues in effect until rescinded in writing.

 /s/ Sheldon B. Derrick                                   /s/ Partner
-----------------------                                  -----------------------
 Signed                                                   Title

 /s/ S. Derrick                                           /s/ April 30/98
-----------------------                                  -----------------------
 Print name                                               Date

<PAGE>

                                                                      APPENDIX I

                                  UNITED STATES
                       SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON. D.C. 20549

    OFFICE OF
THE CHIEF ACCOUNTANT

                                                                November 8, 1996

Mr. Gerry Goldberg
Schwartz Levitsky Feldman
1167 Caledonia Rd.
Toronto, Ontario
Canada M6A 2X1

Dear Mr. Goldberg:

     You have asked whether audit reports of Schwartz  Levitsky Feldman could be
included in filings with the U.S.  Securities and Exchange  Commission  ("SEC").
The staff of the SEC  believes  that in the  interest  of  investor  protection,
financial statements of foreign entities included in filings with the Commission
should  be of a  character  comparable  to those  of  domestic  issuers  (either
directly  through  the  application  of  consistent   accounting  principles  or
indirectly through  reconciliation of material  differences which arise from the
use of differing principles),  and that the examinations of the foreign auditors
should be as extensive as those conducted by U.S.  auditors.  Assuming your firm
is knowledgeable in U.S. generally accepted  accounting  principles and auditing
standards,  and your fir