SecProbe.io

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Mail Stop 4561
									November 16, 2005

Mr. Xi Qun Yu
Chief Executive Officer
China Education Alliance, Inc.
80 Heng Shan Rd.
Kun Lun Shopping Mall
Harbin, P.R. China 150090

      Re:	China Education Alliance, Inc.
		Form 10-KSB/A for Fiscal Year Ended December 31, 2004
		Form 10-QSB for Fiscal Quarter Ended March 31, 2005
		Form 10-QSB for Fiscal Quarter Ended June 30, 2005
		File No. 333-101167

Dear Mr. Yu:

      We have reviewed your response letter dated October 28, 2005
and have the following additional comments.  In our comments, we
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
filings.
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.

1. Please file your response letter dated October 28, 2005 on
EDGAR.

Form 10-KSB/A for the Fiscal Year Ended December 31, 2004

Consolidated Financial Statements

Note 1 - Summary of Significant Accounting Policies and
Organization,
page 17

2. We have reviewed your responses to prior comments 3 and 4 and
still do not understand your revenue recognition policy.  In your
response, you state that "revenue is recognized ... when the debit
cards are delivered and sold by the salesmen or distributors."
However, in your Form 10-KSB, you seem to indicate that revenue is
recognized at the "time of sale to the distributors."  Please
reconcile these inconsistencies for us.  Also, please explain why
you
are unable to track usage when you have told us in your response
to
prior comment 4 that you determine if a debit card user has
sufficient points.

3. Please explain how you have evaluated the criteria in SAB 104
to
conclude revenue should be recognized at the time debit cards are
sold rather than at the time you actually perform services.
Please
specifically tell us how you concluded that services have been
rendered considering the guidance in Question 2 of Topic 13.A.3.f.
Also, please explain the nature of cost of sales related to your
debit card revenue stream and on what basis and over what period
such
expenses are recognized.

4. We note your response to prior comment five.  Please tell us in
detail what guidelines your Board of Directors used in determining
that a ten year useful life was reasonable for these assets.   For
example, relevant factors considered may include historical
experience in the industry, manufacturers` estimates, engineering
estimates, anticipated use(s) and maintenance policies.  Further,
please tell us the historical cost of each of the types of assets
included in communication equipment and the estimated residual
value
assigned to each type of asset.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR.  Please understand that we may have additional comments
after reviewing your responses to our comments.

      You may contact Amanda Sledge, Staff Accountant, at (202)
551-
3473 or the undersigned at (202) 551-3403 if you have questions.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief
Mr. Xi Qun Yu
China Education Alliance, Inc.
November 16, 2005
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