SecProbe.io

September 30, 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 letter da ted August 24, 2011, 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.

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

 General

1. Please note we are unable to clear prior co mments three, four, six, and seven until you
file an actual amendment w ith the changes you provided to us supplementally.  Also,
please note you did not provide us with draft language for co mment five of our letter
dated August 3, 2011, thus we are unable to determine whether your prospective
revisions would be responsive to our comment.

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
September 30, 2011 Page 2

 Corporate Structure and History, page 4
2. We note your response to comment one of our letter dated August 3, 2011, and we
reissue it.  You disclose that Mr. Liu formed Dynamic Elite on June 2, 2010 and Exhibit
10.19 indicates that Mr. Liu personally owned al l of the shares of Dynamic Elite when it
and Mr. Liu entered into the Entrust Agreemen t with Mr. Zhang.  You later disclose that
Crystal Globe was formed to hold all of the outstanding shares of Dynamic Elite and that
Mr. Zhang was appointed as th e executive director of Crystal Globe.  Please revise to
clarify who owned Dynamic Elite when fo rmed, when Crystal Globe was founded and
whether Mr. Liu owned 100% of the Crystal Gl obe from its inception through the report
date of the current report filed on October 7, 2010.  Also, please clarify how and when
Crystal Globe acquired Dynamic Elite from Mr. Liu and the date that Mr. Zhang was
appointed executive director of  Crystal Globe.  On Oct ober 1, 2010, G2 Ventures, Inc.
acquired Dynamic Elite by issuing 15,215,426 shar es of common stock to Crystal Globe.
Thus, Crystal Globe controlled Dynamic Elite through its 92% ownership of the
outstanding shares of G2 Vent ures.  You disclose that the Entrust Agreement gave
“irrevocable authority to make all business, operating and organizational decisions
regarding Dynamic Elite” to Mr. Zhang on page three and effective control of Crystal Globe through his appointment as executive director.  Please revi se to clarify the
references to “effective control” and whether it resulted in the same rights as ownership
and what business, operating and organizationa l powers are still retained by Mr. Liu.  For
example, please clarify whether Mr. Liu has the power to replace Mr. Zhang as the executive director of Crystal Gl obe and the effect of such an  act on Mr. Zhang’s ability to
control Dynamic Elite via the Entrust Agreement.  As previously requested, while you state the founders of the companies, you are not clearly stating wh ether the individuals
who formed the companies were also the contro lling shareholders at that time and before
the transactions described in this section.  La stly, as previously re quested please clarify
whether Mr. Zhang had any ownership, direct ly or indirectly, of Crystal Globe and
Dynamic Elite before the transactions.
3. We note your response to comment two of our letter dated August 3, 2011 that the
amount of consideration was agreed upon orally between the parties.  This would appear
to be an oral amendment to the agreements.  Please provide a written  description of this
amendment as an exhibit.  For guidance, we direct your attention to Question 146.04 to
the Compliance and Disclosure In terpretations, which are found at
http://www.sec.gov/divisions/corpfin/guida nce/regs-kinterp.htm.
Form 10-K for Fiscal Year Ended December 31, 2010

General
4. We note your response to comment eight of  our letter dated August 3, 2011, and we
reissue it.  Please revise your annual report any relevant issue noted in our comments
above and to comply with the prior commen ts issued on the Form 8-K.  Your draft

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
September 30, 2011 Page 3

 disclosures for comments three and four of our letter dated August 3, 2011 should be
included in your amended Form 10-K.  Als o, your prospective revisions related to
comment five of our letter dated August 3, 2011, along with the appr opriate disclosures
of Mr. Zhang’s beneficial ownership of Cr ystal Globe shares, should be included with
your amended Form 10-K.  Also, please revise  to ensure that you remove promotional
language that you are unable to support, such as those described in comment seven of our
letter dated April 13, 2011.

Item 9A. Controls and Procedures
Management’s Annual Report on Internal C ontrol over Financial Reporting, page 57
 5. We reviewed your response to our prior comm ent 9.  Please provide us with a discussion
of the specific roles and res ponsibilities of your Financial Manager and Chief Financial
Officer during their tenure at Ti ens Biotech, Inc.  In your res ponse, ensure to specifically
clarify how each of their role s supported the preparation of that company’s Form 10-K
and other periodic reports.
 6. We reviewed your response to our prior comment 9.  For your Financial Manager and
Chief Financial Officer, please provide us w ith (i) where their uni versity education was
obtained and (ii) the number of  hours of continuing education in U.S. GAAP they have
received individually in the last two years.
 7. We reviewed your response to our prior comments 9 and 10, noting you have hired an
independent accounting firm/consultant to assi st you in the preparation of your Form 10-
K and internal control evaluation.  This appear s to be inconsistent with your response to
our prior comment 25 in your corresponde nce dated December 23, 2010, which states
that you did not retain an outsi de accounting firm or consulta nt to prepare your financial
statements or evaluate your internal contro ls over financial reporting.  Please clarify or
revise.  If this is an accounting firm  that was recently hi red please tell us:
a) The name and address of the accounting firm or organization; b) The level of work performed by this firm; c) When this firm was engaged; d) Where the work was performed; e) The qualifications of their employ ees who perform the services for your
company;
f) How and why they are qualified to prep are your financial stat ements or evaluate
your internal control over financial reporting;
g) How many hours they spent last year  performing these services for your
organization; and
h) The total amount of fees you paid to  each accounting firm or organization in
connection with the preparation of your financial statements and in connection
with the evaluation of internal control ove r financial reporting for the most recent
fiscal year end.

Jinghe Zhang
Joway Health Industries Group In c. (f/k/a G2 Ventures, Inc.)
September 30, 2011 Page 4

8. We have reviewed your response to our prior comment 10 noting you have recently hired
an officer with auditing and financial background who will follow internal accounting
and compliance with Sarbanes-Oxl ey Act of 2002.  Please tell us:
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 trai ning he or she has had relating to U.S.
GAAP;
c) the nature of his or  her contractual or othe r relationship to you;
d) whether he or she holds and maintain s any professional designations such as
Certified Public Accountant  (U.S.) or Certified Ma nagement Accountant; and
e) about his or her professional experience,  including experience in preparing and/or
auditing financial statements prepared  in accordance with U.S. GAAP and
evaluating effectiveness of internal control over financial reporting.

You may contact Angela Hal ac at (202) 551-3398 or Brian Bhandari, Accounting Branch
Chief, at (202) 551-3390 if you have questions regarding comments on the financial statements
and related matters.  Please c ontact Edwin Kim at (202) 551- 3297 or Pamela Howell, Special
Counsel, at (202) 551-3357 w ith any other questions.

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