SecProbe.io

August 3, 2011
Via E-Mail
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: Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
Form 8-K/A
  Filed June 13, 2011   Form 10-K for the Fiscal Year Ended December 31, 2010
Filed April 14, 2011
  File No. 333-108715

Dear Mr. Zhang:
We have reviewed your response and have th e 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.

Form 8-K/A Filed on June 13, 2011

Corporate Structure and History, page 4
1. We reissue comment two of our letter da ted April 13, 2011.  Please revise to provide
clear disclosure as to the ownership of Cr ystal Globe and Dynamic Elite.  Clarify the
entrust agreement and whether the entrust agreement provided Mr. Zhang ownership of
Dynamic Elite.  In addition, as previously requested, while you stat e the founders of the
companies you do not clearly state the controllin g shareholder(s) before  the transactions.
Clarify whether Mr. Zhang had any ownership, directly or indirectly, of Crystal Globe
and Dynamic Elite before the transactions.
2. We reissue comment three of our letter da ted April 13, 2011.  Please revise to disclose
the material terms of the July 25, 2010 and July 28, 2010 share acquisition agreements

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
August 3, 2011 Page 2

 with Chen Jingyum and Wang Aiying to sell their shares to the Joway Group.  In
addition, please advise use whether Exhibits  10.21 and 10.23 are complete.  We note that
these agreements omit the consideration to be paid.
Description of Business, page 11
3. We note your response to comment four of our letter dated April 13, 2011 regarding the
scientific support for your claims  of the benefits of tourmaline.   It appears the studies and
articles cited references some possible bene fits of tourmaline, but your statements still
appear promotional in nature compared to the measured statements cited as support for
your claims.  Please revise to remove the promotional language and provide a more balanced view of the benefits of tourmaline.
4. We reissue comment eight of our letter da ted April 13, 2011.  Please revise your Form 8-
K to describe the business of Shenyang Joway and its similarities and relationships with
the Joway Group.  Also discuss the circumst ances and timing of why and when it ceased
being an operating company.  In 2008 and 2009, Shenyang Joway was one of your largest suppliers, but it is unclear w hy and when it ceased operations and how that impacted your
business.
Security Ownership of Certain Benefi cial Owners and Management, page 60

5. We note that footnote four of your benefici al ownership table is  inconsistent with
footnote five as to who has voting power ove r the shares of Crystal Globe.  Please
reconcile.
Exhibits
6. Please revise the exhibits index, as the *** doe s not indicate where such exhibits can be
found.
7. We note that exhibit 10.20 is missing Appendix 1.  Please file this exhi bit in its entirety.
Form 10-K for Fiscal Year Ended December 31, 2010
General
8. Please revise to your annual report to addre ss any relevant issue not ed in our comments
above and to comply with the prior comments issued on the Form 8-K.
Item 9A. Controls and Procedures
Management’s Annual Report on Internal C ontrol over Financial Reporting, page 57
9. Considering (i) your response to our pr ior comments 24-29 from our letter dated

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

 November 5, 2010 and (ii) your risk factor disc losure on page 33 which states that most
of your accounting and finance staff are not ed ucated and trained in U.S. GAAP and SEC
reporting requirements, please provide us with a detailed discussion of  the factors you
considered in assessing whet her this pervasive issue would result in a significant
deficiency or material weakness and how  this issue was overcome to support your
conclusion that your internal controls over fina ncial reporting were effective at December
31, 2010.
10. Please revise to provide disclosures require d by Item 308(c) of Regulation S-K.  Please
ensure you sufficiently detail all material ch anges to your internal control over financial
reporting that resulted from the share ex change transaction in October 2010.

You may contact Angela Halac at (202) 551-3398 or Brian Bh andari at (202) 551-3390 if
you have questions regarding comments on the fina ncial 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