SecProbe.io

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Mail Stop 0308

							March 28, 2005

Jing An Wang,  Chief Executive Officer
Secured Data, Inc.
16B/F Ruixin Road Bldg.
No. 25 Gaoxin Road
Xi An 710075 Shaanxi Province
China

	RE:	Secured Data, Inc.
		Item 4.01 Form 8-K filed March 18, 2005
            	File No. 0 - 32253

Dear Mr. Wang:

          We have reviewed the above referenced filing and have
the
following comments.  We welcome any questions you may have about
our
comments.  Feel free to contact us at the telephone numbers listed
at
the end of this letter.
1. You have dated your report March 14, 2005; however, you have
not
disclosed why this date is appropriate.  Please revise to state if
you dismissed the former accountants and disclose the date of this
event.  See Item 304(a)(1)(i) of Regulation S-B and revise
accordingly.
2. The second paragraph discusses consultations with Epstein Weber
&
Conover PLC; however, that firm is your former accountant, not
your
newly engaged accountants.  Please revise to provide the
disclosures
required by Item 304(a)(2) of Regulation S-B.
3. The third paragraph, with regard to disagreements, should be
revised to cover the two most recent fiscal years and the
subsequent
interim period through the date of dismissal, if true.  Please
revise.  Also, we believe you should be able to make a positive
statement with respect to disagreements.  Please revise to state
positively if there were disagreements or if there were no
disagreements.
4. In the fifth paragraph of the document you make reference to
Regulation S-K.  It appears you mean to reference Regulation S-B.
Please revise or advise.

Jing An Wang
Secured Data, Inc.
March 28, 2005
Page 2

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  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
disclosures in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

?	the company may not assert this action 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 connection with our review of
your
filing or in response to our comments on your filing.

	The amendment requested above should be filed within five
business days from the date of this letter, or we should be
advised
by that date when it will be filed.  The amendment should include
an
updated letter from your former accountants indicating that they
have
read the Form 8-K/A.  Please file your response to these comments
as
an EDGAR correspondence file at the same time as you file the Form
8-
K/A.  Any questions regarding the above should be directed to me
at
(202) 942-1809, or in my absence, to Robert Benton at (202) 942-
1811.

							Sincerely,

							Robert Burnett
						            Staff Accountant

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