SecProbe.io

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                         [CITY NETWORK, INC. LETTERHEAD]

                                  June 24, 2005

U.S. Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Attention: Thomas Flinn
           Staff Accountant

     Re: City Network, Inc.
         Form 10-KSB for the Fiscal Year Ended December 31, 2004
         Form 10-KSB for the Fiscal Quarter Ended March 31, 2005
         File No. 1-31959

Dear Mr. Flinn:

     City Network, Inc. (the "Company") provides the following responses to the
Staff's letter dated June 15, 2005:

FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2004

Recent Sales of Unregistered Securities, page 21

     1.   We note that on  January  15,  2004 and June 14,  2004 that you issued
          shares of your common  stock at prices  below the quoted  market price
          for your stock per AMEX.  Please  explain  your  business  purpose for
          distributing  your stock at below fair market value. To the extent any
          of  the  participants  in  these   transactions   have  an  employment
          relationship  with your  company,  tell us how you  accounted  for the
          differential  between the quoted  market  price and the shares  values
          used  in the  transactions.  Advise  us why the  differential  did not
          result in compensation expense.

     On January 15, 2004, the Company issued 500,000 shares of its Common Stock
at $1.44 per share pursuant to a private placement exempt from registration
pursuant to Regulation S of the Securities Act of 1933, as amended. The shares
issued were restricted and did not have registration rights. The closing price
of the Common Stock on January 14, 2004 on the American Stock Exchange was $2.45
per share. The Company received aggregate proceeds of $720,000 for this private
placement, which was used to purchase the Company's 40% interest in Beijing
Putain Hexin Network Technology Company Ltd.

     The offering price reflects trading restrictions on the shares, including
the lack of any registration rights and an extreme lack of liquidity of the
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Common Stock, which caused the investors to request a significant discount, and
the lack of other financing alternatives available to the Company.

     None of the subscribers of Common Stock in this private placement were
employees of the Company at the time of or prior to the issuance of the shares.
Therefore, the discount did not result in any compensation expense.

     On June 14, 2004, the Company issued 2,500,000 shares of Common Stock in
exchange for the conversion in full of short term debt to third parties in the
aggregate of $1,680,329. The short term debt was converted at a price of
approximately $0.672 per share. The closing price of the Common Stock on June
10, 2004 (the prior trading day) on the American Stock Exchange was $0.81 per
share. The offering price reflects trading restrictions on the shares, including
the lack of any registration rights and an extreme lack of liquidity of the
Common Stock, which caused the investors to request a significant discount, and
the lack of other financing alternatives available to the Company. Therefore,
the discount did not result in any compensation expense.

     Of the people who received Common Stock in the exchange, twelve, who
received in the aggregate 76,000 shares of Common Stock, were employees of the
Company at the time of the issuance. One of the stockholders, who received
612,000 shares of Common Stock, was not an employee of the Company at the time
but later became an employee of the Company.

Independent Auditor's Report, page F-2

     2.   Please  explain  to us how your  auditors  considered  PCAOB  Auditing
          Standard No. 1 in  conjunction  with their audit  report  contained in
          your Form 10-K.

     The Company's auditors conducted their audit in accordance with the
standards of the Public Company Accounting Oversight Board (United States). The
Company's auditors have revised and reissued their report for the financial
statements included in the Company's Form 10-KSB for the Fiscal Year Ended
December 31, 2004 to reflect such statement. The Company will amend its Form
10-KSB for the Fiscal Year Ended December 31, 2004 to include the reissued
report of the auditors.

FORM 10-QSB FOR THE QUARTER ENDED MARCH 31, 2005

Legal Proceedings, page 20

     3.   We note  from  your  disclosure  that your are  seeking  to  recover a
          receivable  from Hwa-Ching in the amount of $900,000 and that you were
          required to put up a $1.2  million  temporary  guarantee  bond for the
          vendor in the transaction.  We also note that you have only recorded a
          charge of $685,000 related to this  contingency.  Please advise us how
          the amount of expense  recorded  covers the potential loss  associated
          with the bad debt and the lawsuit under SFAS 5.
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     The Company has already fully accrued the amount payable to the vendor,
Rong-Dian, Co. The amount reserved as an allowance is the difference between the
amount of the receivables and the minimum the Company believes it is likely to
recover in the lawsuit, based in part on the assessment of the lawyers handling
the litigation.

     Should the Staff have any questions, please do not hesitate to contact the
undersigned.

                                   Sincerely,

                                   CITY NETWORK, INC.

                                   By: /s/ Tiao-Tsan Lai
                                      ----------------------------
                                   Name: Tiao-Tsan Lai
                                   Title: Chief Executive Officer
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