SecProbe.io

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                                                                 Reed Smith LLP
                                                               435 Sixth Avenue
                                                      Pittsburgh, PA 15219-1886
                                                                   412.288.3131
                                                               Fax 412.288.3063

Michael L. Johnson
Direct Phone:  412.288.7292
Email:  mljohnson@reedsmith.com

                                  May 13, 2005

H. Roger Schwall
Assistant Director
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549-0405

                  Re:
                  Bodisen Biotech, Inc. ("Bodisen")
                  Registration Statement on Form SB-2
                  Filed April 22, 2005
                  File No. 333-124272

Dear Mr. Schwall:

     We  have  reviewed  the  comments  of the  Staff  on  the  above-referenced
registration  statement,  which were set forth in your letter dated May 4, 2005.
On behalf of  Bodisen,  this  letter  responds  to those  comments.  The Staff's
comments  are set forth  below,  followed  by our  response.  Note that all page
numbers  cited in our  responses  below refer to the page numbers in the revised
registration statement. For your convenience, we are separately sending to you a
marked copy of the revised registration statement.

Sources and Availability of Raw Materials, page 19

1.   Reconcile  the statement  that there are  "numerous  suppliers and vendors"
     with Note 15 to the financial  statements  that indicates that four vendors
     provided 70% of your raw material  needs and three vendors  provided 50% of
     your raw material  needs in 2004 and 2003  respectively.  Would the loss of
     any of these suppliers have a material  adverse effect on your  operations?
     If so, provide a risk factor on this point.

     We have explained on page 19 of the  registration  statement in response to
     the Staff's comments,  that Bodisen's  relationships with its vendors,  its
     reputation in the agricultural  community and the industry  practice of not
     relying on written  contracts  provides  Bodisen  with the  flexibility  to
     contract  with  numerous  possible  suppliers  and  vendors.   Bodisen  has
     historically  looked to only a few of the  possible  suppliers  and vendors
     and,  based on the factors  described in the  preceding  sentence,  Bodisen
     believes  that it is in a position to easily  replace any one of its vendor
     so that the loss of any  such  vendor  would  not have a  material  adverse
     effect on its operations.

Signatures, page 34

2.   Please  amend your  registration  statement  to  identify  that  person who
     performs  the  functions  of  principal   accounting  officer.   Also,  the
     registration  statement  must  be  signed  by a  majority  of  your  board.
     Presently only one of your four directors has signed it.
<PAGE>
H. Roger Schwall
May 13, 2005
Page 2

     We have  identified  the  principal  accounting  officer  and  revised  the
     signature  blocks  to  include  all  board  members,  on  page  34  of  the
     registration statement in response to the Staff's comment.

     Thank you for your assistance in this matter.

     If you have any further  questions or  comments,  please do not hesitate to
contact Steve Johnson at (412) 288-7166,  or if he is not available,  you should
contact me at (412) 288-7292.

                                       Sincerely,

                                   /s/ Michael L. Johnson
                                       ------------------
                                       Michael L. Johnson

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