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      RICHARDSON
        & PATEL LLP

      10900
        Wilshire Boulevard

      Suite
        500

      Los
        Angeles, CA 90024

      Telephone
        (310) 208-1182

      Facsimile
        (310) 208-1154

      August
        17, 2005

      VIA
        EDGAR AND FEDERAL EXPRESS

      Securities
        and Exchange Commission

      Division
        of Corporation Finance

      100
        F
        Street, N.E.

      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 August 11,
            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.

              Securities
                and Exchange Commission

              Division
                of Corporation Finance

              August
                17, 2005

              Page
                2

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

              Financial
                Statements

              Consolidated
                Statements of Shareholders' Equity, page F-6

                        1.

                        We
                          refer to your response to comment 6.  Revise future
                          filings to
                          incorporate the proposed disclosure and schedule.
                          Since the table is
                          a reconciliation of the number of shares issued in the
                          merger, please
                          remove the “$” signs prior to incorporation in your
                          filing.

              Response:
                In
                response to your comment, we will remove the “$” signs in the reconciliation of
                the number of shares issued in the merger prior to incorporation
                in our coming
                filings.

              Note
                1
                - Summary of Significant Accounting Policies and Organization, page
                F-8

              Organization

                        2.

                        Your
                          response to comment 9 indicates that the discount rate
                          utilized in
                          determining the present value of an energy savings installment
                          contracts
                          is based on “the best appropriate” under the guidance from paragraphs 12
                          through 14 to APB 21.  Future filings should describe
                          how you
                          determine the discount rate and should describe why you
                          believe your
                          method is appropriate in GAAP.

              Response:
                The
                Company used the best lending rate in China as of the relevant quarter
                ends in
                determining the net present value of notes receivable outstanding
                on energy
                savings sharing contracts at the time the contract was entered into.
                In
                accordance with APBO 21, Interest on Receivables and Payables, the
                Company
                believes that by using this rate reflects what a company would be
                charged on
                this type of transaction if the funds were borrowed from an independent
                lender.
                In future filings we will include a description of how we determine
                the discount
                rate and being an appropriate method under GAAP. The interest rate
                used may be
                subject to change, based upon the prevailing interest rate at the
                period
                end.

                    Securities
                      and Exchange Commission

                    Division
                      of Corporation Finance

                    August
                      17, 2005

                    Page
                      3

              Note
                11 - Taxes Payable, page F-20

                        3.

                        Your
                          response to prior comment 15 indicates that the tax waiver
                          also included
                          the accrued VAT tax.  A VAT tax, when accrued, is
                          normally presented
                          as a reduction of gross revenue as opposed to income tax
                          expense.
                          Based on your income statements, it does not appear that
                          the waived VAT
                          tax was reported as income tax expense as the underlying
                          amounts were
                          accrued.  That is, as sales were made.  Accordingly,
                          tell us why
                          it is appropriate to report waived VAT tax as reduction
                          of income tax
                          expense.  Explain why the income statement classification
                          of this
                          item is appropriate.

              Response:
                The
                Company has treated the waiver of the VAT tax as a reduction of income
                tax
                expense since this was a unique situation as the local Chinese tax
                authority
                granted a one-time waiver for all accrued accumulated taxes prior
                to January 1,
                2004, the Company believes that the presentation of this transaction
                in its
                financial statements was the most conservative approach. The Company
                believes
                that by recording the refund of the VAT tax of $2,477,062 as an addition
                to
                gross revenues would distort the Company’s gross profit and thus be misleading
                as to the actual results of the Company. As part of the Company’s filings the
                Company will include additional disclosures stating the reasons why
                the Company
                has presented this refund in this fashion.

              Forms
                10-QSB for Fiscal 2005

                      4.

                        We
                          refer to your response to comment 16.  As set forth
                          in Regulation S-B
                          an entity is not small business eligible once it
                          reports two
                          consecutive years of revenues in excess of $25 million
                          for both 2003 and
                          2004.  Accordingly, you are not small business eligible
                          as of October
                          1, 2004.  Amend the Forms 10-QSB for fiscal 2005
                          to report on Form
                          10-Q and to provide any other disclosures required by Regulation
                          S-X.

              Response:
                We
                respectfully disagree with your comment. Item 10.a.2.iii of Regulation
                S-B
                provides “once a small business issuer becomes a reporting company it will
                remain a small business issuer until it exceeds the revenue limit…at the end of
                two consecutive years.” In the year 2003, the Company, named Rim Holdings, Inc.
                at the time, reported total revenues of $695,167 on its Annual Report
                for fiscal
                year ended 2003. Such revenue is clearly below the $25 Million revenue
                limit and
                the Company is thus eligible to use Regulation S-B disclosure. Item
                10.a.2.v. of
                Regulation S-B further provides that “the determination (as to the reporting
                category) made for a reporting company at the end of its fiscal year
                governs all
                reports relating to the next fiscal year. An issuer may not change
                from one
                category to another with respect to its reports under the Exchange
                Act for a
                single fiscal year.” As a result, since its reporting category at the end of
                2003 is S-B, the Company’s reporting category for 2004 is also S-B.

                    Securities
                      and Exchange Commission

                    Division
                      of Corporation Finance

                    August
                      17, 2005

                    Page
                      4

              In
                the
                year 2004, the Company acquired a 50% interest in Starway Management
                Limited
                (“Starway”). In the Annual Report of the Company for fiscal year ended 2004,
                the
                Company reported consolidated revenues of $ 30,997,070. We believe
                that since
                the Company acquired only a 50% interest in Starway and under no
                condition would
                the Company be entitled to actually receive more than half of the
                profits of
                Starway, the actual revenues of the Company can only be $15,498,535.
                However,
                even if we agree that the entire $30,997,070 be counted, the Company
                only
                exceeded the revenue limit in 2004. Under the transaction rules provided
                by Item
                10.a.2. of Regulation S-B, the Company continues to be a small business
                issuer
                until the end of the current fiscal year; and assuming that their
                revenues
                exceed $25 Million in 2005, the Company would be subject to Regulation
                S-K
                starting October 1, 2005.

              Based
                on
                this analysis, we respectfully disagree with your comment that the
                Company is
                currently subject to Regulation S-X. The foregoing analysis is based
                on a
                reasonable interpretation of the transition rules currently in effect.
                We have
                researched this issue and did not find any published authorities
                to the
                contrary. If there are authorities that contradict our analysis,
                please feel
                free to forward it and we will be happy to review it. The Company
                is mindful of
                its filing category and pursuant to your comments will begin providing
                disclosures required by Regulation S-K after the end of this fiscal
                year.

              Form
                10-QSB as of March 31, 2005

              Consolidated
                Statements of Cash Flows, page 6

                        5.

                        We
                          refer to the response comment 17.  Future filings
                          should also make
                          disclosure about the business purpose of the
                          loan.

              Response:
                The Company will provide the necessary disclosure of such loan in
                both MD&A
                and footnotes in the coming filings.

              We
                hope
                that the information contained in this letter satisfactorily addresses
                the
                comments by the Staff. Please do not hesitate to contact the undersigned
                by
                telephone at (310) 208-1182, or by facsimile at (310)
                208-1154.

                          Very
            truly
            yours,

                          Richardson
&
            Patel LLP

          /s/
            Kevin
            K. Leung

          Enclosures

                  cc
                    (w/o
                    encs.):

                    Mr.
                      Sun Li, China Energy Savings Technology,
                      Inc.

                    Mr.
                      Dean Yamagata, Moore Stephens