SecProbe.io

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Mail Stop 6010

								July 13, 2005

Jinyuan Li
Chief Executive Officer
Tiens Biotech Group (USA), Inc.
No. 6, Yuanquan Rd.
Wuqing New Tech Industrial Park
Tianjin, China

	Re:	Tiens Biotech Group (USA), Inc.
		Form 10-KSB for the Year Ended December 31, 2004
		Filed March 31, 2005
		File No. 0-49666

Dear Mr. Li:

	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 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.

FORM 10-KSB

Current Products, page 5

1. We note you have a series of personal care products.  Please
describe this series of products.

Business Development Strategy - Marketing and Distribution, page
13

2. Please disclose the percentage of revenues obtained from sales
in
each of the principal countries in which you operate accounting
for
more than 10% of your revenue.

Item 8A. Controls and Procedures, page 48

3. We note management evaluated your disclosure controls and
procedures.  Please disclose either that this evaluation led the
CEO
and CFO to conclude the disclosure controls and procedures are
effective or that this evaluation led the CEO and CFO to conclude
the
disclosure controls and procedures are ineffective.  If they
concluded
the controls are ineffective, please discuss the controls that led
to
this conclusion.  See Item 307 of Regulation S-B.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 1 - Background

4. Please tell us and disclose the accounting treatment of the
reorganization which was effective September 9, 2003.

*	*	*

	As appropriate, please amend your filing and respond to these
comments within 10 business days or tell us when you will provide
us
with a response.  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.

	You may contact Todd Sherman at (202) 551-3665 or Kevin Woody
at
(202) 551-3629 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 551-3861 or me at (202) 551-3715 with any other
questions.

								Sincerely,

								Jeffrey Riedler
								Assistant Director

cc:	Mitchell S. Nussbaum, Esq.
	Loeb & Loeb LLP
	345 Park Avenue
	New York, NY 10154-0037
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Jinyuan Li
Tiens Biotech Group (USA), Inc.
July 13, 2005
Page 1

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