SecProbe.io

January 28, 2011
 Jinghe Zhang, Chief Executive Officer Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
16th Floor, Tianjin Global Zh iye Square, 309 Nanjing Road,
Nankai District, Tianjin, PRC

Re: G2 Ventures, Inc.
Form 8-K
  Filed on October 7, 2010   File: 333-108715

Dear Mr. Zhang:
We have reviewed your responses and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

General

1. Given the large number of outstanding comments, please file an amended Form 8-K to
address the comments below in addition to th e revisions provided in your supplemental
response dated December 23, 2010, as opposed to providing supplemental draft disclosure is a response letter.   Please note that we may have additional comments to
proposed changes in your res ponse letter, depending upon the act ual changes made in the
amended Form 8-K.
2. We note that you have responded that you will revise your Form 8-K to address many of
our comments, but you do not provide specifi c draft disclosure.  We are unable to
determine whether your prospective change s address our concerns.  We reissue
comments 10, 13, 17, 21, 37-42, 44-46, 48, and 50 of our letter dated November 5, 2010.

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
January 28, 2011 Page 2

Entry into a Material Definitive Agreement, page 5
3. We note your response to comment four of our letter dated November 5, 2010, and we
reissue it.  Mr. Zhang Jinghe owns 99% of  the Joway Group and held a controlling
interest prior to the creation of Junhe Consu lting and Dynamic Elite.  Please revise your
current report to clarify the consideration Mr . Zhang Jinghe received in  order to enter into
the VIE agreements which transferred the ec onomic benefits and control of the Joway
Group to Crystal Globe and its subsidiaries .  Also, please revise to clarify the
circumstances or agreements that led Mr. Zh ang Jinghe to become the executive director
of Junhe Consulting.  Clarify who controlled Crystal Globe when it owned Dynamic Elite, and to the extent that Mr. Zhang Jinghe  retains any beneficial ownership of the
shares of Crystal Globe, please revise acco rdingly. To the extent that there are any
agreements, written or otherwise, regarding the ownership or cont rol of Crystal Globe,
please disclose and file as exhibits.
4. We note your response to comment five of our letter dated November 5, 2010, and we
reissue it.  Please incorporat e your response in your ame nded Form 8-K/A as to the
estimated option price.  Also, please clarif y whether Mr. Zhang Jinghe, as the executive
director of Junhe Consulting, has sole discretion in exercising the option.
5. We partially reissue comment six of our letter dated Nove mber 5, 2010.  Please disclose
any relationships, connections or agreements  between Crystal Globe and Zhang Jinghe.
Corporate Structure and History, page 6

6. We reissue comment eight of our letter da ted November 5, 2010.  Please revise to
disclose the material terms of the Ju ly 25, 2010 and July 28, 2010 share acquisition
agreements with Chen Jingyum and Wang Aiying to sell their shares to the Joway Group.
7. We note your response to comment 11 of our  letter dated November 5, 2010, and we
reissue it in part.  Please re vise to briefly describe the Law of the People’s Republic of
China on Wholly Foreign-Owned Enterprises and explain why such local approval is
needed under the regulation.

Description of Business, page 9
8. We note your response to comments 12 and 15 of our letter dated November 5, 2010, and
we reissue them.  We have reviewed your documents that you submitted and are unable to locate any references that “tourmaline is  believed to have th e advantage of improving
human body circulation, relievi ng stress, increasing mental alertness and strengthening
the immune system function.”  Please provi de us supplementally with a table clearly
providing each factual or st atistical statement from the Form 8-K and the specific
location in the source cited for that statement or remove such disclosure.  To the extent

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
January 28, 2011 Page 3

 that you cite to information regarding tour maline gemstone, please provide the basis for
believing this information also applies to liquid tourmaline or pr ovide a citation to
support your belief that liquid tourmaline provi des the same function and benefits as
tourmaline gemstone.
9. We note your response to comment 14 of our  letter dated November 5, 2010, and we
reissue it.  Please advise us th e identity of the supplier that  used the “Joway Group” name
on your website address http://en.joway.cn/page/html/index.php .  Also, please revise to
clarify the relationship between the firms, its use of the Joway group name in other
situations, and whether there is any confusion as to the two en tities.  To the extent that
you used this website, please explain, as the information on the website appeared to be
that of a supplier.
10. Please incorporate your response to comment 22 of our letter dated November 5, 2010 in
your amended report.
11. We note your response to comment 23 of our  letter dated November 5, 2010, and we
reissue it.  Please revise to  provide a more thorough expl anation how the environmental
laws that are listed in your response a pply to the Company and explain why your
environmental compliance costs are minimal.   For instance, you do not explain if the
manufacturer of tourmaline related products do not result in waste po llution, or if you are
exempt from such environmental laws, etc.
12. We note your VIE agreements involve the Joway Group and Junhe Consulting.  Please
explain whether these VIE agreements have be en approved by the appropriate regulatory
authorities.  We note your propos ed revisions in Exhibit A on ly refer to the approval of
the foreign ownership of Junghe Consulting by Dynamic Elite.
Risk Factors, page 29
13. We note from your response to our prior comments 24 through 29 that your financial
statements are prepared in accordance with Chinese GAAP and your CFO is responsible
for reviewing the adjust ments made to the financial statem ents to convert them to U.S.
GAAP.  In addition, you state that your CFO’ s U.S. GAAP experience was obtained from
working for a U.S. listed company.  Please prov ide us with a detailed discussion of the
relevant education  and ongoing training your CFO has had related to U.S. GAAP.
14. We note from your response to our prio r comments 24 through 29 that your CFO is
responsible for reviewing the adjustments made to the fina ncial statements to convert
them to U.S. GAAP.  Please tell us the follo wing as it relates to th e individuals who are
actually preparing  the U.S. GAAP financial statements:
a)  what role he or she takes in preparin g your financial statements and evaluating the
effectiveness of your internal control;
b)  what relevant education and ongoing tr aining he or she has had relating to U.S.

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
January 28, 2011 Page 4

 GAAP;
c)  the nature of his or her contractual or ot her relationship to you;
d)  whether he or she holds and mainta ins any professional designations such as
Certified Public Accountant  (U.S.) or Certified Ma nagement Accountant; and
e)  about his or her profe ssional experience, including expe rience in preparing and/or
auditing financial statements prepared  in accordance with U.S. GAAP and
evaluating effectiveness of internal control over financial reporting.
15. Based on your responses to our prior comment s 24 through 29 regard ing the preparation
of your financial statements and management’s  assessment of your internal control over
financial reporting, please revise  your risk factors that descri be those factors that impact
your ability to prepare financial statements and maintain your books and records in U.S.
GAAP.  These factors would include the fact  that your books and r ecords are maintained
and prepared in PRC GAAP and the employees  who have primary responsibilities of
preparing and supervising the preparation of the financial statements under U.S. GAAP
do not have knowledge of and professional e xperience with U.S. GAAP and SEC rules
and regulations.  In addition, pl ease confirm to us that you w ill evaluate these factors in
the future in concluding on the effectiveness of disclosure co ntrols and procedures under
Item 307 of Regulation S-K and internal cont rol over financial repo rting under Item 308
of Regulation S-K, as applicable.

Management’s Discussion and Analysis  and Plan of Operation, page 42
16. We reissue comment 30 of our letter da ted November 5, 2010.  The Management’s
Discussion and Analysis section is one of the most critical aspects of  your disclosure.  As
such, we request that you revise this sec tion to provide a more detailed executive
overview to discuss the events, trends, and un certainties that management views as most
critical to your future revenues, financia l position, liquidity, plan of operations, and
results of operations, to the extent known and foreseeable.  To assist you in this regard,
please refer to the Commission Guidance Regarding Management’s Discussion and
Analysis of Financial Condition and Resu lts of Operations, Release Nos. 33-8350
(December 19, 2003) at http://www.sec.gov/rules /interp/33-8350.htm.  This guidance is
intended to elicit more meaningful disclosure  in MD&A in a number  of areas, including
the overall presentation and focus of MD&A, with general emphasis on the discussion
and analysis of known trends, demands, co mmitments, events and uncertainties, and
specific guidance on disclosures about liqui dity, capital resources, and critical
accounting.

Liquidity and Capital Resources, page 46
17. We note your response to comment 36 of our  letter dated November 5, 2010, and we
reissue it.  It appears that the CITIC trust investment relates to the periods covered by
your financial statements and management’s di scussion and analysis included with your

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
January 28, 2011 Page 5

 Form 8-K.  Thus, please provide a more deta iled description of the investment trust
product and file it as an exhibit,  or provide us with an analys is why such disclosure is not
necessary.
Executive Compensation, page 59
18. We note your response to comment 43 of our  letter dated November 5, 2010, and we
reissue the comment.  Please revise to cl arify whether the Comp any had any intention
existed, at the time of the reverse merger transaction, to implement a “comprehensive
compensation program” and provide a more detail ed description of such plans.  If the
Company did not design a prospective compen sation plan with such details, as opposed
to implementing such a plan, please clearly revise your disclosure accordingly.  Based on
your response, it is unclear wh ether such a plan existed a nd was abandoned, or whether a
prospective compensation plan never existed.

Certain Relationships and Re lated transactions, page 62
 19. We reissue comment 44 of our letter da ted November 5, 2010.  Please provide the
disclosure required by Item 404 of Regulation S-K regarding th e VIE agreements in this
section, as opposed to  a cross-reference.
 Unregistered Sales of Equity Securities, page 68

 20. We note your response to comment 52 of our  letter dated November 5, 2010, and we
reissue it in part.  Please re vise to provide the facts that  were relied upon to make an
exemption under Regulation S available for your sa le of unregistered securities to Crystal
Globe.
Consolidated Financial Statements

Notes to Consolidated Financial Statements
Note 1 – Organization, page F-6
21. We note your response to our prior comment  55 which indicates that the financial
operations of Tianjin Joway Shengshi Group Co., Ltd. (“Tinjian”) were included for all
periods presented in Dynamic Elite’s financial statements because the transaction in which Dynamic Elite obtained control of Tianjin  was accounted for as a reorganization of
entities under common control.  However, your  response to our prior comment 56 states
the operations of Tianjin were consolid ated by contract unde r FASB ASC 810-10-15.
Please respond to the following:
• If you believe the operations of Tianjin are included in the financial statements of
Dynamic as a result of a reorganization of entities under common control, please

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
January 28, 2011 Page 6

 provide a detailed discussion of the relati onship between these entities before and
after you obtained control, including the level of ownershi p of the parties
involved in the transaction.
• If you believe the operations of Tianjin are included in the financial statements of
Dynamic Elite as a result of  consolidation by contract then please tell us how your
evaluation of this guidance supports your accounting treatment (i.e., the presentation of consolidated historical financial statemen ts) for the period prior to
the date on which you entered into contra ctual agreements with Tianjin Junhe
Enterprise Management  Consulting Co., Ltd.
Exhibits

22. We note your response to comment 64 of our  letter dated November 5, 2010, and we
reissue it.  These exhibits do not appear to  be complete documents and appear to be
missing terms.  For example,  Exhibit 10.13 includes references to “Refer to List” in the
Quantity column.  Please advise us what list is  being referred to and whether it is part of
the sales contract as an attachment, exhibit, or  schedule.  If yes, please file the complete
document, as required by Item 601 of Regulation S-K.

You may contact Ethan Horow itz at (202) 551-3311 or Ange la Halac at (202) 551-3398
if you have questions regarding comments on the financial statements and related matters.
Please contact Edwin Kim at (202) 551-3297 or Pamela Howell, Special Counsel, at (202) 551-
3357 with any other questions.

 Sincerely,
  /s/ Pamela Howell  for
John Reynolds Assistant Director