SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 6010

								September 2, 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/A for the Year Ended December 31, 2004
		Filed August 11, 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/A

Item 8A. Controls and Procedures, page 48

1. We note that in response to comment 3, you state in the
response
letter that the CEO and CFO concluded the disclosure controls and
procedures were effective as of December 31, 2004 and that the
disclosure is revised to reflect that fact.  However, it does not
appear the disclosure was revised.  Therefore, we reissue the
comment.
Please state in an amended Form 10-KSB the CEO and CFO`s
conclusion
regarding the effectiveness of the disclosure controls and
procedures.

*	*	*

	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.

	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
??

??

??

??

Jinyuan Li
Tiens Biotech Group (USA), Inc.
September 2, 2005
Page 1

</TEXT>
</DOCUMENT>