SecProbe.io

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MAIL STOP 3561
      August 5, 2005

Mr. Paul Fong
President & Chief Executive Officer
PortalToChina.com, Inc.
1802-888 Pacific Street
Vancouver, BC  V6Z 2S6
Canada

      Re:	PortalToChina.com, Inc.
	Item 4.01 Form 8-K
      Filed August 2, 2005
	File No. 333-111652

Dear Mr. Fong:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with more
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 filing.
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 me at the telephone number listed
at
the end of this letter.

Form 8-K filed August 2, 2005
1. Please revise to comply with Item 304(a)(1)(iv) of Regulation
S-B
for the period from the engagement of Ernst & Young LLP to their
dismissal.
2. Please amend to file an updated letter from Ernst & Young LLP,
as
an Exhibit 16 in accordance with Item 304(a)(3) of Regulation S-B.
This letter should reflect their agreement or disagreement with
any
disclosures in the amended Form 8-K filing.

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
provide
us with a response.  You may wish to provide us with marked copies
of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	If you have any questions, please call me at (202) 551-3390

							Sincerely,

							Brian K. Bhandari
							Staff Accountant

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Paul Fong
PortalToChina.com, Inc.
August 5, 2005
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