SecProbe.io

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Mail Stop 3561
      November 2, 2005

Li Solomon Kip Yun
Chairman and Chief Executive Officer
Fortune Pharmaceutical, Inc.
Room 811, 8F Xingye Bank Building
Futian District, Shenzhen, 518040  P.R.C.

      Re:	Fortune Pharmaceutical, Inc.
		Registration Statement on Form 10-SB
      Filed October 31, 2005
		File No. 0-51591

Dear Mr. Yun:

      We have limited our review of your filing to those issues we
have addressed in our 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.
Part I
Item 5.  Directors and Executive Officers, Promoters and Control
Persons, page 18

      Describe in column format under the appropriate caption, the
prior experience involving officers, directors, promoters and
affiliates with blank check companies, stating for each the status
of
the filing with the Commission, the filing date, and the file
number.
Also, state whether any acquisitions, business combinations, or
mergers are pending, or have occurred and the current operating
status of each.

Part II

Item 1. Market Price and Dividends on the Registrant`s Common
Equity
and Other Shareholder Matters, page 22

      Please include the number of outstanding securities of the
Company in this section, indicating separately the number of
shares
held by persons who are officers, directors, promoters,
affiliates,
or their transferees.

*******

      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 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 filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Company from its  full responsibility for the adequacy
and accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness
           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 connection with our review of
your
filing or in response to our comments on your filing.

      Please be advised that your registration statement will
automatically become effective 60 days after filing.  Upon
effectiveness, you will become subject to the reporting
requirements
of the Securities Exchange Act of 1934, even if we have not
cleared
your comments.  In the event that it appears that you will not be
able to respond by the 60th day, you may wish to consider
withdrawing
your registration statement and refilling when you have prepared a
response to our comments.  In addition, should the filing become
effective in its present form the Division would be required to
consider what recommendation, if any, it should make to the
Commission.

      Please contact the undersigned at (202) 551-3790 or Goldie
B.
Walker, Financial Analyst, at (202) 551-3234 with any other
questions.

      				Sincerely,

      				Michael E. Karney
      				Branch Chief (Legal)

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Li Solomon Kip Yun
Chairman and Chief Executive Officer
Fortune Pharmaceutical, Inc.
November 2, 2005
Page 3

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