SecProbe.io

Mail Stop 4561         J u n e  1 ,  2 0 0 9   Mr. Stanley Chan President and Chief Executive Officer Scientific Energy, Inc.  27 Weldon Street Jersey City, NJ  07306
Re: Scientific Energy, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2008
Filed April 10, 2009 Form 10-Q for the Quarterly P eriod Ended March 31, 2009
Filed May 20, 2009
 File No. 000-50559

Dear Mr. Chan:

We have reviewed the above-referenced f ilings and have the following comments.
Please note that we have limited our review to only your financial statements and related
disclosures and do not intend to expand our review to other portions of your document.
If 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 supplemental information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
 Please understand that the purpose of our re view 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.

Mr. Stanley Chan
Scientific Energy, Inc.
June 1, 2009 Page 2  Form 10-K for the Fiscal Year Ended December 31, 2008

 Item 9A(T). Controls and Procedures

 Changes in Internal Control Over Financial Reporting, page 27

1. Please revise your statement in future filings to disclose if there were any changes
in your internal control over financia l reporting.  Refer to Item 308T(b) of
Regulation S-K.  Similar concerns appl y to your disclosures in your Form 10-Q
for the quarter ended March 31, 2009.
 Item 15. Exhibits, Financial Statement Schedules

 Exhibit 31

2. We note that the certification by your Pr incipal Executive Officer and Principal
Financial Officer is not set forth exactly  as it appears in It em 601(b)(31)(i) of
Regulation S-K.  Please file a revised certification that includes the introductory
language of paragraph 4 and paragraph 4( b) of Item 601(b)(31)(i) of Regulation
S-K regarding your internal control over financial reporting.  The amendment
may be abbreviated and consist of a cove r page, explanatory note, signature page
and paragraphs 1, 2, 4 and 5 of the certification.

Form 10-Q for the Quarterly Period Ended March 31, 2009

Item 4T. Controls and Procedures
 Evaluation of Effectiveness of Disclosu re Controls and Procedures, page 10

3. We note your disclosure on page 11 stat ing that disclosure controls and
procedures “can provide only reasonable, not absolute, assuran ce that the control
system’s objectives will be met.”  In your response letter, please confirm, if true,
that your Chief Executive Officer and Chie f Financial Officer concluded that your
disclosure controls and procedures were  effective at the reasonable assurance
level as of the end of the period covered by your Form 10-Q.  In addition, ensure
that future reports clarify whether your CEO and CFO have concluded that the controls and procedures are effective at th at reasonable assurance level.  In the
alternative, omit from future filings the re ference to the level of assurance of your
disclosure controls and procedures.  Pl ease see Section II.F.4 of SEC Release No.
33-8238, Management's Reports on Internal  Control Over Financial Reporting
and Certification of Disclosure in Exchange Act Periodic Reports.

* * * * * * *

Mr. Stanley Chan
Scientific Energy, Inc.  June 1, 2009 Page 3
 Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your response to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your response 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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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
filing;
• staff comments or changes to disclosure  in response to staff comments 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 advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 You may contact Ryan Rohn, Staff Accountant, at (202)  551-3739 or me at (202)
551-3730 if you have any questions re garding the above comments.
        S i n c e r e l y ,           Stephen Krikorian
Accounting Branch Chief