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      Unassociated Document

      RICHARDSON
        & PATEL LLP

      10900
        Wilshire Boulevard

      Suite
        500

      Los
        Angeles, CA 90024

      Telephone
        (310) 208-1182

      Facsimile
        (310) 208-1154

      July
        28,
        2005

      VIA
        EDGAR AND FEDERAL EXPRESS

      Securities
        and Exchange Commission

      Division
        of Corporation Finance

      450
        Fifth
        Street, N.W.

      Washington
        DC, 20549

              Attn.:

                Patrick
                  Enunwaonye

                Gary
                  Todd

                Re:

                China
                  Energy Savings Technology, Inc.

                Form
                  10-KSB for the fiscal year ended
                  September 30, 2004

                Form
                  10-QSB for the quarter ended December
                  31, 2004

                File
                  No.
                  000-31047

      Messrs.
        Enunwaonye and Todd:

      On
        behalf
        of China Energy Savings Technology, Inc. (the "Company"), set
        forth
        below are the Company’s responses to the Staff’s comment letter dated July 12,
        2005, with respect to the above-referenced periodic reports of the Company.
        We
        have reproduced the Staff’s comments and have followed each comment with the
        Company’s response. References in this letter to “we,”“our” or “us” mean the
        Company or its advisors, as the context may require.

      Form
        10-KSB for the fiscal year September 30, 2004

      Liquidity
        and Capital Resources, page 20

                1.

                Your
                  response to prior comment 4 states that you analyze accounts and
                  notes
                  receivable for potential bad debts on an annual basis. As a public
                  company
                  you are required to file financial statements on a quarterly basis.
                  Tell
                  us why you should not analyze notes and accounts receivable for
                  bad debts
                  on at least a quarterly basis. If you, in fact, analyze accounts
                  and notes
                  for bad debts only on an annual basis, tell us why this matter
                  is not a
                  weakness in internal control that should be disclosed in the
                  filing.

        Securities
          and Exchange Commission

        Division
          of Corporation Finance

        July
          28,
          2005

        Page
          2

      Response:

      The
        notes
        and accounts receivable for bad debts are reviewed both monthly and quarterly
        on
        a more general basis. The annual review relates to a much more in depth review
        done by the Company in conjunction with preparing for the annual audits.
        Thus,
        the Company does complete general reviews of its accounts and notes receivable
        for potential bad debts on a monthly and quarterly basis and does not believe
        that there is a weakness in internal control that is required to be disclosed
        in
        the filing.

      Financial
        Statements

      Reports
        of Independent Registered Public Accounting Firms, pages F-2 and
        F-3

                2.

                Your
                  response to comment 7 indicates that the CFO is familiar with
                  International Accounting Standards. Your response does not describe
                  any
                  internal expertise in US GAAP. Accordingly, it appears that the
                  company
                  does not have an employee with knowledge of US GAAP. As you are
                  a US
                  public company presenting financial statements under US GAAP, tell
                  us why
                  this matter is not a material weakness in internal controls that
                  should be
                  disclosed in filing.

      Response:

      As
        mentioned in the Company’s response to your last set of comments, the Company’s
        prior Chief Financial Officer is a qualified accountant and with the assistance
        from the Company’s US Auditors, the financial statements of the Company can
        comply with the disclosure requirements under US GAAP. There are no significant
        reporting and accounting differences when the Company converts its financial
        statements to US GAAP to comply with US reporting standards. Thus, the
        assistance that the US Auditors provided to the Company is relatively minimal
        in
        the reporting process. Additionally, effective July 1, 2005, the Company
        hired
        Mr. Lawrence Lok Yuen-Min as CFO of the Company. Mr. Lok has a Master’s Degree
        in Economics (with a major in professional accounting) from Macquarie
        University, Sydney NSW Australia. Mr. Lok is an Australian chartered accountant
        and has over 20 years experience in the areas of accounting and finance.
        Mr. Lok
        has knowledge and experience in accounting and reporting under US GAAP
        standards. Whenever there is a difference between US GAAP standards and
        International Accounting Standards, Mr. Lok will search and study the difference
        in order to comply with US GAAP standards. As a result, the Company does
        not
        believe that it has a material weakness in internal controls that needs to
        be
        disclosed in its filings.

                3.

                As
                  a related matter, as required by Sarbanes-Oxley Section 302 your
                  officers
                  certified that the financial statements fairly present your company's
                  financial condition, results of operations and cash flows. Those
                  financial
                  statements are prepared according to US GAAP. In light of your
                  response to
                  comment 7 and the apparent absence of internal expertise in US
                  GAAP, tell
                  us how your officers satisfied themselves that the financial statements
                  were, in fact, appropriately presented under US GAAP. Your response
                  should
                  be detailed and specific.

        Securities
          and Exchange Commission

        Division
          of Corporation Finance

        July
          28,
          2005

        Page
          3

      Response:

      The
        Company believes that there are no significant reporting and accounting
        differences between US GAAP and the conversion of the Company’s financial
        statements to comply with US GAAP and US reporting standards. With the hiring
        of
        the Company’s new CFO, Mr. Lok, the Company believes that it has added to its
        expertise in US reporting and believes that the certifications under section
        302
        of SOX are appropriate.

                4.

                You
                  also indicate that your underlying records are maintained in Chinese
                  GAAP
                  and that those records were translated to US GAAP with assistance
                  from the
                  US-based auditors. Describe to us, in detail, the nature and extent
                  of
                  participation of the auditors in translation of accounting records
                  from
                  Chinese GAAP to US GAAP.
                  Respond separately for each audit firm. Your response should fully
                  describe the involvement of each audit firm in this
                  process.

      Response:

      In
        the
        case of both audit firms, the Company’s accounting personnel converts and
        arrives at the proposed journal entries to convert the Company’s books from
        Chinese GAAP to US GAAP based upon the direction and supervision of the
        Company’s CFO. The US audit firms will audit the account balances and proposed
        journal entries to ensure that the accounts are recorded and presented in
        accordance with US GAAP. Any adjustments proposed by the US audit firms during
        the regular course of the audit are discussed with management to ensure that
        the
        Company’s financial statements are presented in accordance with US
        GAAP.

                5.

                With
                  respect to the Webb & Company audit, please identify the correspondent
                  firm used to translate Company's records to English. Also tell
                  us whether
                  the Webb & Company employees speak Chinese. If they do not, tell us
                  how those auditors were able to communicate with your Chinese
                  employees.

      Response:

      Certain
        employees and the senior management including the CFO of both the Company
        and
        its subsidiaries in Shenzhen can communicate in English and have helped the
        Company translate the relevant documents that are written in Chinese into
        English. Moreover, most of the Board members could provide assistance in
        oral
        communication as well as translation of all relevant documents from Chinese
        into
        English.

          Securities
            and Exchange Commission

          Division
            of Corporation Finance

          July
            28,
            2005

          Page
            4

          Consolidated
            Statements of Shareholders' Equity, page F
            6

                6.

                We
                  see your responses to comments 10 and 11; however, disclosure about
                  the
                  share transactions continues to be unclear. The statement of shareholders'
                  equity shows 12,338,301 shares issued in the recapitalization.
                  Yet,
                  financial statement footnote 1 indicates that you issued 11,153,669
                  shares
                  in the transaction. As well, it is not clear how the statement
                  of
                  shareholders' equity reflects the shares redeemed tram Ms. Strauch.
                  Provide us a clear reconciliation between the footnote and the
                  statement
                  of shareholders' equity. We may have comment on disclosure upon
                  review of
                  your response.

      Response:

      In
        response to your comment, the Company proposes the following changes to its
        disclosure:

      Following
        footnote number 1 the Company proposes to revise the portions
        underlined:

      On
        June
        30, 2004 (“the Closing Date”) Rim Holdings Inc., a Nevada corporation (Rim) and
        Eurofaith Holdings, Inc., a British Virgin Islands Corporation (“Eurofaith),
        entered a Stock Purchase Agreement (the Eurofaith Stock Purchase Agreement).
        Pursuant to the Stock purchase agreement, Rim acquired 50% of the outstanding
        shares of Starway Management Ltd., a British Virgin Islands company (“Starway”)
        from Eurofaith (the “Acquisition”). The purchase price for such stock was
        $120,000,000 payable by Rim’s issuance of a convertible promissory note on the
        Closing Date. The note may be convertible into 223,073,380 shares of the
        Rim’s
        common stock upon maturity at the discretion of Rim. Eurofaith may also convert
        at any time prior to the maturity. On June 30, 2004, the fair value of the
        convertible note payable was discounted to the fair value of the equity interest
        acquired of $6,633,440 which is 50% of the net book value of Starway as December
        31, 2003. On August 26, 2004 this note was converted into 11,153,669 shares
        post-split of 20 to 1 (223,073,380 pre split). New Solomon Consultants Limited
        acquired 6.9 million shares of common stock from Eurofaith Holdings upon
        conversion. (see Note 15).

      Immediately
        after the closing of this transaction, Rim redeemed 1,000,000 pre
        split shares
        (50,000
        shares post split) of
        its
        common stock from Christina M. Strauch in exchange for all of the shares
        of
        Rimmer Computer, Inc., an Arizona corporation (“Rimmer”).

      In
        addition, the Company proposes to add the following table:

          Securities
            and Exchange Commission

          Division
            of Corporation Finance

          July
            28,
            2005

          Page
            5

        The
          following is a summary of the shares issued due to the
          recapitalization:

                No.
                  of Shares

                Issued

                  Shares
                    issued to current stock holders in connection with
                    recapitalization

                $

                1,234,632

                Shares
                  issued to Eurofaith due to note conversion

                11,153,669

                Shares
                  redeemed from Christina Strauch

                (50,000

                )

                Net
                  shares issued due to recapitalization

                $

                12,338,301

        Revenue
          and Deferred Revenue Recognition, page F-12

                  7.

                  Your
                    responses to comments 14 and 15 indicate that you have post-shipment
                    obligations for training, seminars and three years of free maintenance.
                    You indicate that you believe that these items need not be separately
                    accounted for because the cost of these services is minimal.
                    In general,
                    under EITF 00-21, the fair value of each element is separately
                    recognized
                    in revenue as those elements are delivered. The cost of delivery
                    is not
                    the sole consideration or driver of the accounting. In a detailed
                    response, demonstrate that the application of EITF 00-21 would
                    not be
                    material. Your response should fully demonstrate how you evaluated
                    the
                    requirements of the EITF and should fully explain the basis for
                    your
                    conclusion that the impact of guidance is not material. We may
                    have
                    further comment upon review of your
                    response.

        Response:

        The
          Company has post-shipment obligations for training, seminars and three
          years of
          free maintenance to its customers. Under EITF 00-21, revenue arrangements
          with
          multiple deliverables should be divided into separate units of accounting:
          (1)
          if the deliverables in the arrangement meet that the delivered items have
          value
          to the customer on a stand-alone basis, (2) there is objective and reliable
          evidence of the fair value of the undelivered items, (3) the arrangement
          includes a general right of return relative to the delivered item, delivery
          or
          performance of the undelivered item(s) is considered probable and substantially
          in the control of the vendor.

            Securities
              and Exchange Commission

            Division
              of Corporation Finance

            July
              28,
              2005

            Pa