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      RICHARDSON
        & PATEL LLP

      10900
        Wilshire Boulevard

      Suite
        500

      Los
        Angeles, CA 90024

      Telephone
        (310) 208-1182

      Facsimile
        (310) 208-1154

      September
        1, 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 18,
              2005 with respect to the above referenced periodic reports of the Company.
              We
              have reproduced the Staff’s comment and have followed the 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.

            Forms
              10-QSB for Fiscal 2005

                      1.

                      We
                        refer to your response to prior comment 4. In reverse merger
                        transactions
                        the financial statements of the accounting acquirer become
                        the financial
                        statements of the registrant pursuant to GAAP. In these instances
                        we look
                        to the financial statements of the accounting acquirer in
                        assessing
                        continuing SB eligibility. The amounts of revenues report
                        by Rim Holdings
                        prior to the reverse merger are not relevant under reverse
                        merger
                        accounting and are not considered in assessing the continuing
                        SB
                        eligibility of the accounting acquirer. China Energy’s financial
                        statements report audited
                        revenues totaling $30,997,070 in fiscal 2004 and $31,057,877
                        in fiscal
                        2003. Accordingly, China Energy has reported two consecutive
                        years of
                        audited revenues in excess of $25 million. Under Regulation
                        S-B China
                        Energy exited the small business reporting system on October
                        1, 2004.
                        Appropriately amend the Forms 10-QSB for fiscal 2005 to report
                        under
                        Regulation S-X.

            Response:
              We
              agree that GAAP requires that the financial statements of the accounting
              acquirer be presented as the financial statements of the registrant.
              However, we
              find no statutes, regulations, literature, published rulings, telephone
              interpretations that suggest we look to the “accounting” acquirer in assessing
              S-B eligibility. We believe that the determination of S-B eligibility
              is a
              matter of law and not accounting rules.

              Securities
                and Exchange Commission

              Division
                of Corporation Finance

              September
                1, 2005

              Page
                2

              Regardless
                of the accounting treatment of Rim Holdings’ acquisition of the shares of
                Starway, under state corporate and securities laws, Rim Holdings,
                an S-B filer,
                acquired an interest in the shares of Starway. Rim Holdings’ reporting
                obligations under the Securities Act and the Exchange Act did not
                change upon
                such acquisition.

              We
                note
                again that 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, Rim Holdings, Inc., reported total revenues of $695,167 on
                its Annual
                Report on Form 10-KSB 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.

              In
                the
                year 2004, the Company acquired an 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 transition 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 again believe that the Company is currently subject
                to
                Regulation S-B. 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.

              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