SecProbe.io

April 13, 2011
 Via Fax and Mail

Jinghe Zhang, Chief Executive Officer Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
16th Floor, Tianjin Global Zhiye 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.

Form 8-K filed with Correspondence on February 28, 2011

General
1. We reissue comment one of our letter dated January 28, 2011.  Please provide an
amended Form 8-K to addre ss our comments and incorpor ate your previous responses
you have made in a draft format.  Also, please include the exhibits that you represent in
your response letters that will be file d with an amended Form 8-K/A.

Entry into a Material Definitive Agreement, page 3
2. We note your responses to comments three and five of our letter dated January 28, 2011
regarding the indirect ownership of Crystal Globe and partially reissue the comments.
Please revise to provide clear disclosure as to the ownership of Crystal Globe and
Dynamic Elite.  You state that Mr. Liu form ed these companies but do not specifically
clarify who was the controlling shareholder befo re and/or after the tr ansactions.  In this
regard, we note that the disclosure provide d in your supplemental response to comment
21 is clearer than the disclosure in the propos ed changes to the Form 8-K.  In addition,
clarify whether Mr. Zhang had any ownership or control, directly or indirectly, of Crystal
Globe and Dynamic Elite before the transactions.  Please revise this section and footnote four of your beneficial ownership table to clarify the individuals that have indirect
ownership of Crystal Globe, and thus, control of your operating subsidiaries , as it appears

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
April 13, 2011 Page 2
 that Mr. Zhang is the ultimate beneficial owner and control pers on and therefore the
shares should be included in the table fo r Mr. Zhang or advise as to why you believe
disclosure is not  required.
Corporate Structure and History, page 4

3. We note your response to comment six of our  letter dated January 28, 2011.  Please
revise to disclose the material terms of the July 25, 2010 and July 28, 2010 share
acquisition agreements with Chen Jingyum a nd Wang Aiying to sell their shares to the
Joway Group.

Description of Business, page 11
4. We reissue comment eight of our letter date d January 28, 2011.  We are unable to locate
the supplemental table as st ated in your response lett er dated February 28, 2011.
5. We reissue comment 13 of our letter date d November 5, 2010.  Please clarify whether
you have a website.  If so, please provide the address.
6. We are unable to find the revisions you provide d in response to comment 17 of our letter
dated November 5, 2010 with regard to the mate rial terms of your franchise agreement.
The draft language you provided in your res ponse letter dated D ecember 23, 2010 is not
in the business discussion.  Fu rther, you previously indicated  that you would file a form
franchise agreement, but you have not yet provided such document and the exhibits index does not reflect a franchise agreement.  Please revise accordingly.
7. We note your revisions in res ponse to comment 20 of our le tter dated November 5, 2010
that the Company “believes it is the leadi ng manufacturer and dist ributor of tourmaline
healthcare-related products in the PRC” and th at “we have the most matured tourmaline
particle attachment technol ogy in the PRC.”   Please provide the basis for these
statements or remove.
8. We note your response to comment nine of our letter dated January 28, 2011, and we
reissue it in part.  Please revi se to briefly describe the bus iness of Shenyang Joway and its
similarities and relationships with the Jo way Group.  Also, please advise us whether
Shenyang Joway uses the Joway Group name as part of its business.
Risk Factors, page 36

9. We note your response to comment 15 of our  letter dated January 28, 2011 and the
related revisions to your filing.  As noted in ou r prior comment, please confirm to us that
you will evaluate the factors outlined in your re vised risk factor disclosure in concluding
on the effectiveness of disclosure controls and procedures under Item 307 of Regulation
S-K and internal control over financial report ing under Item 308 of Regulation S-K in the
future.

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
April 13, 2011 Page 3

Executive Compensation, page 67

10. We note your response to comment 42 of our  letter dated November 5, 2010, and we
reissue it.  Please revise to clarify that th e compensation figures and discussion includes
all compensation, including any from Junhe  Consulting and/or Dynamic Elite.  In
addition, there should only be one summary co mpensation table providing the disclosure
required by Item 402(n) of Regulation S-K.

Market Price of and Dividends on the Regist rants Common Equity and Related Stockholder
Matters, page 76
 11. We reissue comment 48 of our letter dated November 5, 2010.  Please provide the market
price information required by Item 201(a)(1)(iii) of Regulation S-K.  Although thinly
traded, we note that the stock has been quoted on the OTC Bulletin Board under the stock
symbol GVTI.
Dynamic Elite International Limited Consolidated Financial Statements

General
 12. Please amend your Form 8-K to include updated interim financial statements of Dynamic
Elite International Limite d for the nine months ended September 30, 2010 and 2009.
Refer to Exchange Act Rules 13a-1 and 13a-13.

Exhibits

 13. We note your responses to comments 10 a nd 17 of our letter dated November 5, 2010,
and comments 17 and 22 of our letter date d January 28, 2011 in which you indicate you
will file various documents as exhibits to your amended Form 8-K/A.  Please file these
documents, as we are unable to clear these comments unless we are able to review these
exhibits.  Please also note that we may ha ve additional substantive comments regarding
the disclosure in the Form 8-K once we review these exhibits.
 14. We note your response to comment 22 of our le tter dated January 28, 2011 that the other
exhibit 10.13, the agreements are complete.  Pl ease clarify whether these are forms of the
agreement or whether these are the execute d agreement.  If these are the executed
agreement, we note that exhibits 10.11, 10.12 and 10.13 are also missing the quantity and
amount, and therefore the exhibits  should be filed in their enti rety.  If these are forms of
the agreement, please advise and explain why the executed agreements are not filed.

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
April 13, 2011 Page 4

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