SecProbe.io

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Mail Stop 6010								June 23, 2005

David Gao
Beijing Med-Pharm Corporation
1180 Main Street
Coventry, CT 06238

Re:	Beijing Med-Pharm Corporation
	Registration Statement on Form S-1
      Amended June 14, 2005
	File Number 333-121957

Dear Mr. Gao:

	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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

Beijing-Med Pharm Corporation and Subsidiary
December 31, 2004 Financial Statements,  page F-8
Notes to the Consolidated Financial Statements page F-12
Note 1. Significant Accounting Policies, page F-12

Revenue Recognition, page F-12

1. We note your revised disclosure as a result of our prior
comment
number seven.  It appears that you do not provide for returns
because
they have been "neither consistent nor material". Please tell us
how
this policy complies with GAAP, specifically FASB No. 48 and
clarify
your disclosure accordingly.

Beijing Wanwei Pharceutical Co. Ltd.
Notes to the Financial Statements
8. Segment Information, F-34

2. We have read your June 14, 2005 response and revised disclosure
in
response to comment 11 of our May 23, 2005 letter.  The
disclosures
required by paragraph 37 of FAS 131 are enterprise wide
disclosures
rather than segment disclosures. Please refer to paragraph 36.
Please
tell us further why the fact that Wanwei has over 300 customers
and
that no customer accounts for over 7% of Wanwei`s revenue makes
providing the information required by paragraph 37 impracticable
and
not meaningful as this paragraph does not relate to major
customers.

Pro Forma Financial Statements, F-38 through F-43

3. Please remove the December 31, 2004 pro forma balance sheet as
the
March 31, 2005 balance sheet is now the most recent balance sheet
required. Please refer to rule 11-02(c) of Regulation S-X.

*	*	*

	As appropriate, please amend your registration statement in
response to these comments.  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.  We may have
additional comments after reviewing your amendment and responses
to
our comments.

      You may contact Tabitha Akins at (202) 551-3658 or James
Rosenberg at (202) 551-3679 if you have questions regarding
comments
on the financial statements and related matters.  Please contact
Michael Reedich at (202) 551-3612 or me at (202) 551-3710 with any
other questions.

      Sincerely,

      Jeffrey Riedler
      Assistant Director

cc:	Joanne Soslow, Esq.
	Morgan, Lewis & Bockius
	1701 Market Street
	Philadelphia, PA 19103
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