SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

January 29, 2008
  Mr. Kevin Halter Jr. President, Rub A Dub Soap, Inc. 2591 Dallas Parkway, suite 102 Frisco, TX  75034
Re: Rub A Dub Soap, Inc.
Form 10-KSB for the fiscal year ended May 31, 2007 Form 8-K filed November 14, 2007 File No. 0-52142

 Dear Mr. Halter:
We have reviewed your filing and have th e 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 commen t is inapplicable or a revision is unnecessary.
Please be as detailed as necessa ry 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 or  may not raise additional comments.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements 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 on any other aspe ct of our review.  Feel free to call us at
the telephone numbers listed at  the end of this letter.

Form 10-KSB for the period ended May 31, 2007

Evaluation of Disclosure Cont rols and Procedures, page 9

1. We note your disclosure that “Based on your  evaluation…your disclo sure controls and
procedures were designed to ensure that ma terial information relating to the Company is
made known…”  Your disclosu res do not indicate if your officers determined based on
their evaluation, that your disclosure cont rols and procedures were effective or
ineffective.  Please confirm to us, and revise future filings to clarify, if true, that your officers concluded that your di sclosure controls and procedures are effective.  See
Exchange Act Rule 13a-15(e).  This comment is also applicable to your Form 10-Qs for
the periods ended August 31, 2007 and November 30, 2007.

Mr. Kevin Halter, Jr.
Rub A Dub Soap, Inc.
January 29, 2008 Page 2

Form 8-K filed November 14, 2007

Financial Statements
General

2. We note that you have entered into a st ock purchase agreement with Zhongsen
International Company Group, Lt d.  Please clarify for us w hy you have not included the
financial statements of Zhongsen Internat ional Company Group, Ltd. but instead have
included the financial statements of its subs idiaries.  In addition, please clarify why the
financial statements of  Qi ngdao Free-Trading Zone Sentaida International Trade Co.,
Ltd., Qingdao Sentaida Tires Co., Ltd, a nd Zhongsen Trading Co., Ltd have been
presented on a combined basis.  In this rega rd, please clarify if these subsidiaries operate
under common control.

3. Please tell us what consideration you gave to  including the quarterly financial statements
of the subsidiaries of Zhongsen Interna tional Company Group, Ltd. in accordance with
Item 310 of Regulation S-B.
 Combined Statements of Cash Flows, page 4

4. Please tell us how you determined it was a ppropriate under SFAS 95 to include your
restricted cash balances in the beginning and ending cash and cash equivalents balances.

Note 2. Summary of significant accounting policies
Revenue Recognition

5. With a view towards future disclosure, pl ease provide us with a more specific and
comprehensive discussion of how you have considered SAB 104.  In this regard, please
also clarify if you recognize reve nue upon shipment of your products.
 As appropriate, please amend your filing a nd respond to these comments within 10
business days or tell us when you will provide us  with a response.  Please provide us with a
supplemental response letter that keys your re sponses to our comments and provides any
requested supplemental information.  Detailed letter s greatly facilitate our review.  Please file
your supplemental response on EDGAR as a corres pondence file.  Please understand that we
may have additional comments after reviewing your responses to our comments.
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes all information require d under the Securities and
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.

Mr. Kevin Halter, Jr.
Rub A Dub Soap, Inc.
January 29, 2008 Page 3

In connection with responding to our comment s, please provide, in writing, a statement
from the company acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclosure in their filings;
• staff comments or changes to disclosure in re sponse to staff comments do not foreclose the
Commission from taking any action w ith 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 advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.
If you have any questions regarding these comments, please direct them to Mindy
Hooker, Staff Accountant, at (202) 551-3732, Tricia Armelin, St aff Accountant, at (202) 551-
3747 or to the undersigned at (202) 551-3768.

Sincerely,    John Cash Branch Chief