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      Unassociated Document

        CHINA
          ENERGY SAVINGS TECHNOLOGY, INC.

        Central
          Plaza, Suite 3203A, 32/Floor

        18
          Harbour Road

        Hong
          Kong, China

      November
        1, 2005

      VIA
        EDGAR AND FACSIMILE

      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:

            Please
              let this letter serve as confirmation of the understanding reached
              between China
              Energy Savings Technology, Inc. (the "Company") and the Staff regarding
              the
              Company’s periodic report filings for fiscal year ended September 30, 2005.
              Pursuant to our understanding, we will not be required to re-file our
              quarterly
              reports for the quarters ended December 31, 2004, March 31, 2005 and
              June 30,
              2005 (which were filed using Form 10QSB, referred to herein as the
“Quarterly
              Reports”) on Form 10Q. The Company hereby represents that each of the Quarterly
              Reports is not misleading as filed and amended and there would be no
              significant
              or material differences between filing such reports on Form 10Q as
              opposed to on
              Form 10QSB. We also understand that we are required to file our annual
              report
              for the fiscal year ended September 30, 2005 on Form 10K (as opposed
              to on Form
              10KSB).

              Securities
                and Exchange Commission

              Division
                of Corporation Finance

              November
                1, 2005

              Page
                2

                We
                  hope
                  that the information contained in this letter satisfactorily addresses
                  all of
                  the comments by the Staff. Please do not hesitate to contact us
                  or our legal
                  counsel, Kevin K. Leung of Richardson & Patel LLP, at (310) 208-1182, or by
                  facsimile at (310) 208-1154 should you have further questions or
                  comments.

                  Very
                    truly
                    yours,

                    China
                      Energy Savings Technology, Inc.

                    By:

                  /s/
                    Sun Li

                    Sun
                      Li

                    Chief
                      Executive Officer

                  cc:

                    Mr. Dean
                      Yamagata, Moore Stephens