SecProbe.io

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Mail Stop 3-9
                 December 7, 2004

Brett R. Chapman, Esq.
General Counsel
WH Holdings (Cayman Islands) Ltd.
P.O. Box 309GT
Ugland House, South Church Street
George Town, Grand Cayman, Cayman Islands

Re:	WH Holdings (Cayman Islands) Ltd.
	Amendment No. 4 to
	Registration Statement on Form S-1
	File Number 333-119485

Dear Mr. Chapman:

      We have reviewed your amended 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 supplemental 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 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.
S-1/Amendment No. 4

Business, page 70

1. We note your response to comment 8 of our letter dated November
29, 2004 and the prospectus disclosure appearing in Amendment No.
4
to the registration statement.  With respect to the discussion on
page 70 concerning your product development efforts, please also
disclose that, unlike drug products that must be proven safe and
effective for their intended use before marketing, there are no
provisions in the law for the FDA to "approve" dietary supplements
for safety or effectiveness before they reach the consumer.

Product Development, page 78

2. We note your response to comment 15 and the associated
revisions
to the prospectus.  With respect to your disclosure of $254,000 in
fixed costs for the clinical studies at UCLA, please explain why
such
amount was given as $420,000 in your response 78 of your previous
letter of November 9, 2004.

*	*	*

      As appropriate, please amend your filing in response to
these
comments.  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 supplemental information.  Detailed cover letters
greatly facilitate our review.  Please file your cover letter on
EDGAR under the form type label CORRESP. Please understand that we
may have additional comments after reviewing your amendment and
responses to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Frank Wyman at (202) 942-2851 or Lisa
Vanjoske
(202) 942-1972 if you have questions regarding comments on the
financial statements and related matters.  Please contact Daniel
Greenspan at (202) 942-2974 or me with any other questions.

Sincerely,

Jeffrey Riedler
Assistant Director

cc:	Jonathan K. Layne, Esq.
Gibson, Dunn & Crutcher LLP
	2029 Century Park East
	Los Angeles, CA 90067

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Brett R. Chapman, Esq.
WH Holdings (Cayman Islands) Ltd.
Page 1 of 2
December 7, 2004

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