SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>rimletter.txt
<DESCRIPTION>COMMENT LETTER - ITEM 4 8-K (GILMORE)
<TEXT>

September 2, 2004

Mail Stop:  4-6

Lee Kam Man
Chief Executive Officer and acting
Chief Financial Officer
China Energy Savings Technology, Inc.
(formerly Rim Holdings Inc.)
22/F Morrison Commercial Building
31 Morrison Hill Road
Wan Chai, Hong Kong
China

Re:	Item 4 Form 8-K filed August 24, 2004

Dear Mr. Man:

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 us at the telephone numbers listed at the end of this
letter.

1. Item 304(a)(1)(ii) of Regulation S-K requires a statement whether
the accountant`s report on the financial statements for either of the
past two years contained an adverse opinion or a disclaimer of opinion
or was qualified or modified as to uncertainty, audit scope or
accounting principles; and a description of the nature of each such
adverse opinion, disclaimer of opinion, modification or qualification.
This would include disclosure of uncertainty regarding the ability to
continue as a going concern in the accountant`s report.  Please revise
to include both fiscal years.
2. The disclosure should also state 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.  Please revise to include both fiscal years.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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 respond to these comments within 5 business days or tell us
when you will provide us with a response.  Please furnish a cover
letter with your amendment that keys your responses to our comments
and provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.

Please file your cover letter on EDGAR.  Please understand that we may
have additional comments after reviewing your amendment and responses
to our comments.  You may contact the undersigned at 202-824-5355 if
you have questions regarding these comments.

Sincerely,

Patrick Gilmore, CPA
Staff Accountant
Lee Kam Man
Rim Holdings, Inc.
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