SecProbe.io

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                      SICHENZIA ROSS FREIDMAN FERENCE LLP

                                                              January 31, 2005

VIA EDGAR, FACSIMILE (202) 942-9533
AND FEDERAL EXPRESS

Mail Stop 3-9
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

         Attn:    Jeffrey Riedler, Assistant Director
                  Zafar Hasan, Esq.
                  Ms. Dana Hartz
                  Ms. Lisa Vanjoske

         Re:      China Health Holding, Inc.
                  Registration Statement on Form SB-2
                  File No. 333-119034

Ladies and Gentlemen:

         The following responses address the comments of the reviewing Staff of
the Commission as set forth in a comment letter dated January 3, 2005 relating
to the Registration Statement on Form SB-2 of China Health Holding, Inc. (the
"Company"). On behalf of the Company, we respond as follows.

General
-------
1.       We note your new disclosure relating to p values for DFU898 on page 13
         of the registration statement. Please provide more information
         regarding the p values, including an introductory sentence that
         explains what a p value is and explaining what you mean by "getting
         something more extreme than our results." Please use simple and
         specific terms that will be easy for investors to understand.

         Response

         As per your request, more information was added to the disclosure on
         page 13 regarding the p values. An explanation of p values was provided
         in simple and specific terms that should be easy for investors to
         understand.

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Securities and Exchange Commission
January 31, 2005
Page 2 of 2

Item 26. Recent Sales of Unregistered Securities (page II-2)
------------------------------------------------------------

2.       We note your response to comment 16, but continue to believe that
         shares issued on the same day or close proximity should have the same
         fair value. It appears there may be a compensatory value that may need
         to be recorded at the issuance of the shares. Please revise the filing
         or explain to us what factors have led to different fair values.

         Response

         The company has modified its accounting treatment of share issuances to
         comply with the Staff's observation that shares issued on or about the
         same day should be recorded for accounting purposes all at the same
         fair value. Based on management's estimate of fair value, the result of
         this change in the Company's financial statements as at September 30,
         2004 was an increase in share capital of $287,134 and increase in the
         reported accumulated deficit of $287,135. The disclosure under Item 26
         and the financial disclosure throughout the registration statement has
         been revised accordingly.

         After consulting FDA counsel, the Company determined to revise certain
other sections of the registration statement. Specifically, the Company revised
certain disclosure as it relates to FDA regulation on pages 4-5, 12-14, 15,
17-19 and 21-22.

         We trust that the foregoing appropriately addresses the issues raised
by your recent comment letter. Thank you in advance for your prompt review and
assistance.

                                                  Very truly yours,

                                                  /s/ David Schubauer
                                                  ------------------
                                                  David Schubauer

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