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      Bestway
        Coach Express Inc.

      2
        Mott
        Street, 7th
        Floor

      New
        York,
        NY 10013

      December
        13, 2005.

      By
        EDGAR Transmission and by Hand Delivery

      Pamela
        A.
        Long

      Division
        of Corporation Finance

      U.S.
        Securities and Exchange Commission

      100
        F
        Street, N.E.

      Washington,
        D.C. 20549

              Re:

                Bestway
                  Coach Express Inc.

                Registration Statement
                  on Form
                  10-SB

                Filed July 15,
                  2005

                File Nos. 0-51437.

      On
        behalf
        of Bestway Coach Express Inc. (Bestway or the Company), we hereby submit
        Bestway’s responses to the comments of the staff (the Staff) of the Securities
        and Exchange Commission (the Commission) set forth in the Staff’s letter, dated
        August 8, 2005, providing the Staff’s comments with respect to the above
        referenced registration statement (the Registration Statement) and the Staff’s
        letter, dated December 7, 2005, regarding Bestway’s compliance with its
        reporting requirements under section 13(a) of the Securities Exchange Act
        of
        1934.

      For
        the
        convenience of the Staff, each of the Staff’s comments
        is
        included and is followed by the corresponding response of Bestway. References
        in
        this letter to “we”, “us” and “our” refer to Bestway unless the context
        indicates otherwise.

      1.
        Update
        your filing to include interim financial statements as of and for the six
        months
        ended May
        31,
        2005. See Item 310(g) of Regulation S-B.

      Bestway
        response: We
        have
        amended the Registration Statement to include interim financial statements
        as of
        and for the nine month period ended August 31, 2005.

      Background,
        page 3

      2.
        Identify the casino locations in Connecticut to which Bestway Coach Express
        provides motorcoach service.

      Bestway
        response: We
        have
        revised the registration statement to name the casinos that we provide
        motorcoach service to. Specifically, we provide service to the Mohegan Sun
        Resort and Casino in Connecticut and the Tropicana, Taj Mahal, Claridge and
        Trump Marina in Atlantic City, New Jersey.

      3.
        Provide consistent disclosure for your revenue percentages here and in the
        table
        on page 13.

      Bestway
        response: We
        inadvertently inserted the incorrect percentages in the Background section
        of
        the Registration Statement. We have revised those percentages so that they
        are
        now consistent with the table on page 13.

      Equipment,
        page 5

      4.
        We
        note that in about May / June 2005 Bestway Coach Express acquired 11 new
        MCI
        motorcoaches and traded in an equal number of older Van Hool motorcoaches.
        Tell
        us the carrying amount at the date of trade of the 11 older coaches, the
        trade-in amount, and how Bestway Coach Express accounted for the
        purchase/trade-in transactions. We assume that the 11 MCI motorcoaches acquired
        are new, 2005 model year.

      Bestway
        response: We
        have
        revised the Registration Statement to indicate the carrying amounts of the
        coaches at the trade in dates. The carrying value of the first three coaches
        that were traded in during May 2005 was $515,223, and the trade-in amount
        of
        such coaches, in the aggregate, was $401,631. The carrying value of the
        remaining eight coaches that were traded in during June 2005 was $1,632,662,
        and
        the trade-in amount of such coaches, in the aggregate, was $1,165,156. Bestway
        Coach accounted for the transactions as a purchase.
        We also confirm that the 11 MCI motorcoaches are new 2005
        motorcoaches.

      5.
        We
        note the disclosure on page F-7 and elsewhere that Bestway Coach Express
        leases
        all of its motorcoaches from various financing companies. Revise the disclosure
        here to clarify whether the 12 Van Hool motorcoaches are leased. If the 12
        Van
        Hool motorcoaches are leased, file the lease agreements as exhibits to the
        Form
        10-SB.

      Bestway
        response:
        We have
        revised the disclosure on page F-7 to indicate that as of November 30, 2004,
        all
        of the Company’s motorcoaches were leased. We have also filed the lease
        agreements as exhibits to the Form 10-SB.

      6.
        Update
        the status of your plan to replace the remaining 12 Van Hool motorcoaches,
        and
        disclose the costs for their replacement.

      Bestway
        response: We
        are in
        the process of negotiating the terms of the acquisition of the remaining
        12 new
        MCI motorcoaches. We expect to take delivery of five of these motorcoaches
        before the end of January 2006. The purchase price per coach for these
        motorcoaches will be the same as the purchase price per coach of the 11
        motorcoaches that we acquired in May 2005. However, MCI has indicated that
        it is
        not willing to give us the same trade-in value for our 12 remaining Van Hool
        motorcoaches that it gave us for the 11 Van Hool motorcoaches that we already
        traded in. We continue to negotiate this issue with MCI.

          2

      Business
        Risks, page 9

      7.
        State
        the deductible amount under each insurance policy.

      Bestway
        response: We
        have
        revised the risk factor relating to insurance under “Business Risks” to disclose
        that the deductible per occurrence, per vehicle is $25,000.

      Concentrated
        Control Risks, page 10

      8.
        Disclosure in the last paragraph on page 10 that Bestway Coach Express has
        no
        employment agreement with Mr. Wilson Cheng is inconsistent with disclosure
        on
        page 15 and elsewhere that Bestway Coach Express entered into an employment
        agreement with Mr. Cheng on June 5, 2005. Please revise.

      Bestway
        response: We
        have
        removed the incorrect disclosure on page 10 that states that Bestway has
        no
        employment agreement with Mr. Cheng.

      Market
        Risks, page 11

      9.
        Disclosure in the second paragraph on page 12 that Bestway Coach Express
        has
        11.7 million shares of common stock outstanding is inconsistent with disclosure
        on page 24 and elsewhere that Bestway Coach Express has 13,680,000 shares
        of
        common stock outstanding as of July 14, 2005. Please revise.

      Bestway
        response:
        We have
        revised the disclosure in the Registration Statement to change the incorrect
        reference to 11.7 million shares being outstanding to be consistent with
        the
        correct reference to 13,680,000 shares being outstanding.

      Management’s
        Discussion and Analysis, page 12

      10.
        Add
        disclosure about the frequency of your bus services, such as on a weekly
        or
        daily basis, and the typical utilization of your buses, thus allowing the
        readers of your financial statements to understand your passenger potential
        that
        could affect your ability to generate revenue.

      Bestway
        response: We
        provide daily service from areas around New York City to casinos in Connecticut
        and Atlantic City, New Jersey. From Monday through Thursday of each week,
        we
        have 17 roundtrip schedules to and from the Mohegan Sun Casino & Resort in
        Connecticut and destinations around New York City. On Friday through Sunday,
        we
        increase the number of our roundtrip schedules to the Mohegan Sun to 19.
        We
        provide 5 roundtrip schedules from Monday through Thursday from New York
        City to
        the following Atlantic City Casinos: Tropicana, Taj Majal, Claridge and Trump
        Marina. We increase the number of roundtrip schedules to these Atlantic City,
        New Jersey casinos to 7 Friday through Sunday. On average, we charter about
        one
        motorcoach per day to third parties during the week and about 2-3 motorcoaches
        during the weekend. In addition, we would like to advise the Staff that for
        the
        most part, our special destination services and our charter services are
        provided on a contracted basis and not a per seat basis. Therefore, customer
        load factors generally do not materially affect our ability to generate
        revenues. We have revised the Registration Statement to further clarify this
        point.

          3

Operating
        Results for Fiscal Year 2004 compared to 2003, page 15

      11.
        Quantify in more detail to the extent possible your results of operations
        to
        help readers better understand changes from one year to the next. For example,
        quantify the material components that impacted the change in sales and operating
        expenses year over year. See Release No. 33-8350.

      Bestway
        response:
        We have
        revised the disclosure under the caption “Operating Results for Fiscal Year 2004
        Compared to 2003 (Audited)” to provide more detail regarding the change in our
        results of operations from year to year.

      12.
        We
        note that fuel costs are a significant component of your operating costs.
        Describe Bestway Coach Express’ strategy and any actions that it has taken to
        deal with rising fuel costs. Also discuss Bestway Coach Express’ ability or
        inability to pass increased costs to customers.

      Bestway
        response: In
        order
        to mitigate the rising cost of fuel, since January 2004 we have used a strategy
        of purchasing fuel whenever possible from those states in which we operate
        (Connecticut and New Jersey) where fuel costs are less than our operating
        base
        (NY). We have not employed any hedging strategies to assist us in mitigating
        the
        rising fuel costs and we have no current intention to do so. We are often
        able
        to pass on increased fuel expenses to our customers by increasing our rates.
        For
        example, we increased the rates that we charge to one of the casinos that
        we
        provide services to by 8% during the period from January 2004 to present
        and we
        raised the rates that we charge to two other casinos during the same period
        by
        15 to 28%. However, the market is very competitive and we are not certain
        that
        we will continue to be able to recoup increased fuel costs by passing them
        on to
        our customers.

      Liquidity
        and Capital Resources, page 17

      13.
        Your
        analysis of your liquidity and capital resources, particularly your cash
        flow
        analysis, should not be recitation of changes and other information evident
        to
        readers from your financial statements. Rather, your analysis should provide
        your readers with information that will allow them to assess your prospects
        for
        the future. Expand this section in your filing to address the items discussed
        in
        section N of Release No. 33-8350.

      Bestway
        response: We
        have
        revised our Liquidity and Capital Resources section to provide more fulsome
        disclosure that will allow readers of the registration statement to better
        assess our prospects for the future. This new disclosure includes, methods
        by
        which we plan to increase cash flow, enhance liquidity and reduce expenses.

      Description
        of Property, page 20

      14.
        We
        note the disclosure that Bestway Coach Express leases an administrative office
        and a garage depot. Since the facilities appear to be material to Bestway
        Coach
        Express’ business, advise what consideration you have given to filing the lease
        agreements as exhibits to the Form 10-SB.

      Bestway
        response: Based
        upon the Staff’s comment, we have reconsidered the materiality of these
        agreements and have opted to file them as exhibits to the Registration
        Statement.

          4

15.
        We
        note your disclosure that the lease on your Brooklyn garage increases from
        $9,000 to $9,500 per month beginning on February 1, 2007. Confirm to us that
        you
        are recognizing your rent expense on this lease on a straight line basis
        over
        the life of the lease in accordance with FASB Technical Bulletin
        85-3.

      Bestway
        response: We
        intentionally did not recognize the rent expense on the lease of the Brooklyn
        garage on a straight line basis over the life of the lease because the results
        of doing so would have been clearly inconsequential to a reader of the financial
        statements. The aggregate difference to date of recording the expense on
        a
        straight-line basis is $5,153 (as of August 31, 2005), and the difference
        at the
        date of increase (February 1, 2007) would be $12,000. As the annual expense
        is
        currently $108,000 and will be raised to $114,000, the amount of misstatement
        over an annual period is clearly inconsequential. It seems unreasonable to
        accept the administrative burden of recognizing the $12,000 difference over
        the
        72 months of the lease.

      Security
        Ownership of Certain Beneficial Owners and Management, page 21

      16.
        Disclosure on page 24 indicates that two million shares were issued to Mr.
        Wilson Cheng in May 2005. Add a subsequent event footnote that discloses
        all
        material equity transactions occurring after the date of the latest interim
        financial statements presented. Also, your disclosure on page 12 on the number
        of shares outstanding is out of date. It states that 11,700,000 common shares
        are outstanding.

      Bestway
        response:
        Because
        the audit report date of February 28, 2005 was before the date of issuance
        of
        this stock, we have not included the issuance as a subsequent event footnote
        in
        the annual report. We have updated the interim financial statements so that
        we
        now provide financial statements for the period ended August 31, 2005. These
        updated interim financial statements provide disclosure regarding the issuance
        of 2 million shares to Mr. Cheng in June 2005. No equity transactions occurred
        after the issuance of these shares. We have revised all incorrect references
        in
        the Registration Statement to reflect the correct number of shares outstanding.
        Please note, however, that the shares were issued to Mr. Cheng in June of
        2005
        and not in May. References to the shares being issued in May were erroneous.
        We
        have corrected all of the erroneous references in the Registration
        Statement.

      17.
        Provide us your analysis to determine the fair value of the two million shares
        issued to Mr. Wilson Cheng and how this transaction was recorded.