SecProbe.io

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                       SICHENZIA ROSS FRIEDMAN FERENCE LLP
                           1065 AVENUE OF THE AMERICAS
                                   21st FLOOR
                               NEW YORK, NY 10018
                              (212) 930-9700 PHONE
                               (212) 930-9725 FAX

November 18, 2005

VIA EDGAR AND FEDERAL EXPRESS
-----------------------------

Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549

         Attn:    Cecilia D. Blye, Chief
                  Office of Global Security Risk

                  Jack Guggenheim, Esq.

         Re:      China Health Holding, Inc.
                  10-KSB for the Fiscal Year Ended December 31, 2004
                  10-QSB for the Fiscal Quarnter Ended June 30, 2005
                  File No. 333-119034

Ladies and Gentlemen:

     The following  response  address the comment of the reviewing  Staff of the
Commission as set forth in a comment letter dated November 3, 2005 (the "Comment
Letter")  relating  to the  Annual  Report  on Form  10-KSB  for the year  ended
December 31, 2004 and the Quarterly  Report on Form 10-QSB for the quarter ended
June 30, 2005 of China Health  Holding,  Inc. (the  "Company").  The answers set
forth herein refer to each of the Staffs'  comments by number.  On behalf of the
Company, we respond as follows.

General
-------

1.   We note that on pages 9 of your  10-QSB  filed  August  15,  2005,  for the
     quarterly  period ended June 30, 2005, you state that you have entered into
     two  licensing  agreements  on March 9,  2004,  with  Hotway  Nutraceutical
     Canada,  Co. Ltd.  The first  agreement  granted  licenses to 19  cordyceps
     products  and  the  second  agreement  granted  licenses  to  De-Daibe  and
     Depressor Herbs neutraceutical  products. Both agreements cover a number of
     countries,  including  Iran.  In  light  of the  fact  that  Iran  has been
     identified by the U.S. State Department as a state sponsor of terrorism and
     is  subject  to  economic  sanctions  administered  by  the  U.S.  Treasury
     Department's  Office of Foreign Assets Control,  please describe for us the
     extent  of  your  past,  current  and  anticipated  contacts,  or  intended
     contacts, directly or indirectly, with Iran; the materiality to you of your
     contacts;  or  intended  contacts,  with Iran,  and your view as to whether
     those  contacts  constitute a material  investment  risk for your  security
     holders.  In preparing your response  please  consider that  evaluations of
     materiality should not be based solely on quantitative  factors, but should
     include  consideration of all factors that a reasonable investor would deem
     important in making an investment decision,  including the potential impact

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Securities and Exchange Commission
November 18, 2005
Page 2 of 2

     of corporate  activities  upon a company's  reputation and share value.  In
     this  regard,  we note  that  legislation  requiring  divestment  from,  or
     reporting  of  interests  in,  companies  that do business  with  countries
     designated  as state  sponsors of terrorism  has  recently  been adopted by
     Arizona and Louisiana.

     Response
     --------

     The  Company has no past,  current or  intended,  communications,  personal
     contacts or contracts,  directly or  indirectly,  of any nature  whatsoever
     including  through  licensees  or  intermediaries,  with Iran  and/or  with
     entities in Iran.  Thirty three (33)  countries  were listed in each of the
     license  agreements.  Iran was  included  simply as part of the  process to
     compile a list  including  all  countries in the  geographical  territories
     licensed to Hotway Neutraceutical Canada, Co. Ltd. ("Hotway").  The Company
     is presently  and will at all times in the future be fully  compliant  with
     all US Government regulations dealing with export restrictions. As a result
     of Hotway's  non-compliance  with the license  agreements,  the Company has
     terminated the license  agreements.  In the future, the Company will ensure
     that all international  license  agreements  indicate that any country that
     has been  identified  by the U.S.  State  Department  as a state sponsor of
     terrorism  or is subject to  economic  sanctions  administered  by the U.S.
     Treasury  Department's Office of Foreign Assets Control, or is in any other
     way  proscribed by the United  States,  will not be a territory  under such
     license  agreements  until such time as that  country has been removed from
     such list of state sponsors of terrorism or any other  restricted  list and
     is not  subject to economic  sanctions  by the U.S.  Treasury  Department's
     Office of Foreign Assets Control.

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

                                                 Very truly yours,

                                                /s/ Richard A. Friedman
                                                -----------------------
                                                Richard A. Friedman, Esq.

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