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      CHINA
INFRASTRUCTURE CONSTRUCTION CORPORATION

      C915
Jia Hao International Business Center

      116
Zizhuyuan Road Haidan District

      Beijing,
China 100097

      Tel.
86-10-5170-9287

      Fax 86-10-8844-8198

                January
      20, 2010

      Mr.
Ernest Greene

      Division
of Corporation Finance

      U.S.
Securities and Exchange Commission

      100 F
Street, N.E.

      Washington,
D.C. 20549

                RE:

                China
      Infrastructure Construction Corporation

                  Form
      10-K for Fiscal year Ended May 31, 2009

                  File No.
      333-146758

Dear Mr.
Greene:

      Reference is made to your comment
letter, dated January 13, 2010, relating to the subject Form 10-K (the “Comment
Letter”).  Set forth below are the comments contained in the
Comment Letter followed by our response thereto:

      3. Summary of Significant
Accounting Policies, page F-6

      General

                2.

                We
      have read your response to comment six from out letter dated October 1,
      2009. On page F-7, you indicate that all costs incurred for shipping and
      handling are included in cost of sales. However, in your proposed
      disclosure you indicate that out bound freight costs are included in
      selling, general, and administrative expenses. Please clarify whether all
      shipping and handling costs are included in cost of sales. If shipping and
      handling costs are significant and are not included in cost of sales,
      please disclose both the amounts of such costs and the line item(s) on the
      income statement that include them. Refer to
  EITF-00-10.

      Mr.
Ernest Greene

      U.S.
Securities and Exchange Commission

      January
20, 2010

      Page
2

      Response:

      We have
revised the following footnote in our footnote 3 Summary of Significant
Accounting Policies:

      “Cost of Goods
Sold

      Cost of
goods sold consists primarily of the costs of the raw materials, shipping and
handling charges, direct labor, depreciation of plant and machinery, warehousing
cost and overhead associated with the manufacturing process and commission
expenses.

      Selling, General and
Administration Expenses

      Selling,
general and administrative expenses include costs incurred in connection with
performing selling, general and administrative activities such as executives and
administrative and sale employee salaries, related employee benefits, office
supplies, and professional services (legal and audit).”

                3.

                We
      read your response to comment seven from our letter dated October 1, 2009.
      Please revise your footnote to disclose in manner similar to your
      supplemental response that rewards or incentives given to your customers
      are treated as a reduction of
revenue.

      Response:

      We have
revised the following footnote in our footnote 3 Summary of Significant
Accounting Policies:

      “Revenue
Recognition

      The
Company receives revenue from sales of concrete products. The Company's revenue
recognition policies are in compliance with ASC 605 (previously Staff Accounting
Bulletin 104). Sales revenue is recognized at the date of shipment to customers
when a formal arrangement exists, the price is fixed or determinable, the
delivery is completed, no other significant obligations of the Company exist and
collectability is reasonably assured. Our sales are non-returnable. Therefore,
we do not estimate deductions or allowance for sales returns. Payments received
before all of the relevant criteria for revenue recognition are satisfied are
recorded as unearned revenue.

      Our
products delivered to customers would be checked on site by customers and, once
the products are accepted by customers, they will sign the acceptance notice.
There is no warranty issue after the delivery.

        Mr.
Ernest Greene

        U.S.
Securities and Exchange Commission

        January
20, 2010

        Page
3

      Reward or
incentive given to our customers is an adjustment of the selling prices of our
products therefore the consideration is characterized as a reduction of revenue
when recognized in our income statement.

      The
Company recognizes its revenues net of value-added taxes (“VAT”).  The
Company is subject to VAT which is levied at the rate of 6% on the invoiced
value of sales. However, the Company enjoys a free VAT policy according to the
national policy, which encourages the development of the cement industry if
the manufacturer satisfies the environmental protection requirements. The
Company has enjoyed the free VAT policy from January 1, 2006 and has been
reviewed every year by the local tax bureau.”

      Thank you
for your assistance and cooperation.

                China
      Infrastructure Construction Corporation

                By:

                /s/
      Yiru Shi

                Yiru
      Shi

                Chief
      Financial Officer