SecProbe.io

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Mail Stop 3561
								July 26, 2005

Zhao Ming, CEO and President
Purezza Group Inc.
426 Xuefu Street
Taiyuan
Shanxi Province
China

Re:	Purezza Group Inc.
	Item 4.01 Form 8-K
      Filed July 22, 2005
	File No. 333-85306

Dear Mr. Ming:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with more
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

      You state, "there were no disagreements with Durland...,
except
that the report of Durland for such period indicated conditions
which
raised substantial doubt about the company`s ability to continue
as a
going concern."  We do not understand why such disclosure in the
audit report would be an exception to the fact that there were no
disagreements with the former auditors.  Please revise your
disclosure accordingly.  Also, we reviewed the reports issued for
the
years ending December 31, 2004 and 2003 and did not note any
disclosure of uncertainty regarding the company`s ability to
continue
as a going concern.  Please revise your Form 8-K to disclose
whether
the former accountant`s report on the financial statements for
either
of the past two years contained an adverse opinion, a disclaimer
of
opinion, or was qualified or modified as to uncertainty, audit
scope
or accounting principles, and also describe the nature of each
such
adverse opinion, disclaimer of opinion or modification.  Refer to
Item 304 (a)(1)(ii) of Regulation S-B.

      You state that you have engaged Moore Stephens of New York,
New
York.  We did not see this firm listed on the PCAOB registry with
a
location in New York.  Please revise to state the name that the
accounting firm is registered under with the PCAOB.

      Please revise paragraph (b) to disclose whether written or
oral
advice was provided that was an important factor considered by the
company in reaching a decision as to the accounting, auditing or
financial reporting issue.  Refer to Item 304 (a)(2)(8) of
Regulation
S-B.

      To the extent that you amend the Form 8-K to comply with our
comments, please obtain and file an updated Exhibit 16 letter from
the former accountants stating whether the accountant agrees with
your updated Item 304 disclosures, or the extent to which the
accountant does not agree.

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
respond.
You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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
disclosure 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 staff comments 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 our review of your filing or in
response to our comments on your filing.

	If you have any questions, please call Babette Cooper at
(202)
551-3396.

							Sincerely,

							Babette Cooper
							Staff Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE

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