SecProbe.io

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Mail Stop 0308

							April 8, 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 as amended April
7,
2005
            	File No. 0 - 32253

Dear Mr. Wang:

          We have reviewed the above referenced filings 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. In our comment letter of March 28, 2005 we asked you make
certain
representations in writing and file those representations as an
EDGAR
correspondence file.  We do not see where you have done this.
Please
revise to do so.
2. From information publicly available from the Public Company
Accounting Oversight Board (PCAOB), it does not appear that either
Jimmy C. H. Cheung & Co. or Kreston International are registered
with
the PCAOB.  Please tell us your plans with respect to engaging an
independent accountant who is registered with the PCAOB or advise.
3. Please revise your filing to state if the dismissal of Epstein
Weber & Conover was approved by the Board of Directors.  See Item
304(a)(1)(iii) of Regulation S-B and revise accordingly.
4. In prior comment three we asked you to make a positive
statement
as to whether or not there were any disagreements.  We do not see
how
you responded to this comment since the disclosure in paragraph
three
still states that you are not aware of any disagreements.  Please
either revise the disclosure or tell us why you believe it is
appropriate.

Jing An Wang
Secured Data, Inc.
April 8, 2005
Page 2

5. The disclosure in the first sentence of the fifth paragraph is
not
clear to us.  The information required by Item 304(a)(1) of
Regulation S-B may not be included as an exhibit, and in fact it
does
not appear to be.  You are correct that the letter required by
Item
304(a)(3) of Regulation S-B should be included as an exhibit.
Please
revise or advise.
6. The information in the fourth paragraph should be revised to
comply with Item 304(a)(1)(ii) of Regulation S-B.  As written, you
do
not state if any report included an adverse opinion, or disclaimer
of
opinion, or was modified except as you have disclosed.  Also, it
is
not clear what period you are referring to in the first part of
the
first sentence of the fourth paragraph.  Please revise to clearly
cover the period specified in Item 304(a)(1)(ii) of Regulation S-
B.
If the former auditor did not issue a report for each of the past
two
years, we suggest that you disclose this fact.

	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
another 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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