SecProbe.io

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      May 3, 2006

Via U.S. Mail

Jana Meyer
Secretary
Scientific Energy, Inc.
630 North 400 West
Salt Lake City, Utah  84103

Re:	Scientific Energy, Inc.
Information Statement Pursuant to Section 14(f) of the Securities
Exchange Act of 1934 and Rule 14f-1 thereunder
Filed April 27, 2006
File Number 5-81735

Dear Ms. Meyer:

      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
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 us at the telephone numbers listed
at
the end of this letter.
Schedule 14f-1
Voting Securities and Ownership of Certain Beneficial Owners and
Management, page 3
1. In the future, please note that the footnotes to the beneficial
ownership table should identify the natural person who controls,
i.e.
voting or investment power, the stock owned by the entities listed
in
the table.  See Exchange Act Rule 13d-3.  For example, you should
have disclosed the natural person who controls the common stock
owned
by Kelton Capital Group Limited.

Board of Directors Information, page 5

2. In the future, please revise to ensure that you have provided
all
of the information required pursuant to Item 7(d) of Schedule 14A.
For example, you indicate that the Company does not maintain a
separate audit, compensation or nominating committee, however, you
have not stated the basis for the view that it is appropriate for
you
to not have a nominating committee, pursuant to Item 7(d)(2).
Further, note that even where the company does not have any
defined
policy or procedures for shareholder recommendations, you must
provide the basis for the board`s apparent view that it is
appropriate not to have a policy regarding the consideration of
director candidates recommended by security holders and a process
for
security holders to send communications to the board pursuant to
Items 7(d)(2)(ii)(F) and 7(h)(1) of Schedule 14A.

Schedule 13D filed April 14, 2006
3. Please be advised that where the statement on Schedule 13D is
filed by a corporation, the information called for by Items 2-6
must
be given with respect to each executive officer and director
and/or
controlling person of the corporation.  See Instruction C to
Schedule
13D.  We note that Kelton Capital Group Limited is the filing
person
on this Schedule 13D, however, it does not appear that the
information required pursuant to Instruction C has been provided.
Please revise to provide this information.
4. Further, it is not clear whether a representative of Kelton
Capital Group Limited has executed the Schedule 13D on behalf of
Kelton, considering it states that it was executed by William G.
Hu,
on behalf of Stanley Chan, without any indication of Mr. Chan`s
relationship to Kelton.  Further, as it appears that the statement
is
being signed on behalf of Mr. Chan, evidence of Mr. Hu`s authority
to
sign on behalf of Mr. Chan should be filed with the statement,
pursuant to Item 7.  Please revise to provide this information.

Form 8-K filed on April 20, 2006
5. We note that this document was filed pursuant to Item 5.01 of
Form
8-K.  In light of the election of directors pursuant to the change
of
control transaction, it would appear that Item 5.02 would also be
applicable to this change of control transaction.  Please revise
to
file an amended Form 8-K reflecting this additional item and the
related disclosure, or tell us why you believe this item is not
applicable to this transaction.

Closing comment

      As appropriate, please amend your filing and respond to
these
comments within 10 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 supplemental 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 filings reviewed by the staff to
be
certain that they have provided all information investors require.
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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

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.
      Please direct any questions regarding our comments to me at
(202) 551-3264.  You may also reach me via facsimile at (202) 772-
9203.

								Sincerely,

								Mara L. Ransom
								Special Counsel
								Office of Mergers and
Acquisitions

cc via facsimile (801) 733-0808:

Leonard E. Neilson, Esq.

Scientific Energy, Inc.
May 3, 2006
Page 1 of 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3628

         DIVISION OF
CORPORATION FINANCE

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