SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

 Mail Stop 4631
March 29, 2010

Via U.S. Mail

Li Shun Qing
Chief Executive Officer
China Ceramics Co., Ltd. c/o Jinjiang Hengda Ceramics Co., Ltd. Junbing Industrial Zone Anhai, Jinjiang City
Fujian Province, PRC

 RE: China Ceramics Co., Ltd.
Amendment No. 1 to Form F-1
Filed March 15, 2010
  File No. 333-164784

Dear Mr. Li:
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 w ill consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, 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.

General

1. We have considered your response to comment one in our letter dated March 3,
2010.  We remain concerned that the proposed transaction could be a primary offering.  In our view, the following facts suggest strongly that the proposed offering is a primary offering:
• the selling security holders acquired the subject securities from the registrant
in November 2009 and have subsequently held those securities for
approximately five months;
• the selling security holders are a ffiliates of the registrant; and

Li Shun Qing
China Ceramics Co., Ltd. March 29, 2010 Page 2
• the aggregate number of securities being registered (32,079,083 shares) on
behalf of the selling secur ity holders is well more than three times the size of
the number of shares currently outstanding (8,950,171).
If you wish to proceed with the offeri ng, you should identify the selling security
holders as underwriters and revise the pr ospectus accordingly.  In addition, unless
you are eligible to conduct an at-the-market offering pursuant to Rule 415(a)(4), the selling security holders  must offer and sell the securities covered by the
registration statement at a fixed price rath er than at prevailing market prices.

*     *     *     *

As appropriate, please amend your regist ration 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 cove r 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.
You may contact Hagen Gane m, Staff Attorney, at (202) 551-3330 or Dietrich
King, Staff Attorney, at (202) 551- 3338 if you have any questions.

       S i n c e r e l y ,
 Pamela A. Long  Assistant Director

cc: Mitchell S. Nussbaum, Esq. (via facsimile)
 Loeb & Loeb LLP