AMERICAN ORIENTAL BIOENGINEERING, INC.



United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C.  20549
Mr. Jim B. Rosenberg, Senior Assistant Chief Account
Ms. Tabatha Atkins, Staff Account
Mr. Oscar Young, Senior Staff Account

Ladies and Gentlemen:

We are writing to you in response to your letter to us dated April 17, 2006
containing certain questions relating to our Form 10-KSB for the year ended
December 31, 2005 ("Letter").

The numbered paragraphs set forth below respond to the Staff's comments and
correspond to the numbered paragraphs in the Staff's Letter.

         1. Item 10(a)(1)(v) of Regulation S-B provides that "The determination
made for a reporting company at the end of its fiscal year governs all reports
relating to the next fiscal year. [Emphasis added.] An Issuer may not change
from one category to another with respect to its reports under the Exchange Act
for a single fiscal year."

         In reliance on the first sentence above, the determination made by us
at the end of fiscal year 2005 that we are no longer deemed to be a small
business issuer, as defined under Item 10 of Regulation SB, will govern all
reports commencing with fiscal year 2006. As such, our quarterly report for the
quarter ended March 31, 2006 will be our first Exchange Act report when we are
no longer within the small business reporting category. The second sentence
appearing above further supports this position. All of our reports under the
Exchange Act for the fiscal year 2005 (i.e., our quarterly reports on Form
10-QSB for each of the quarters ended March 31, June 30 and September 30) have
been consistent with our small business reporting category. If the Company were
to file its annual report for the year ended December 31, 2005 on Form 10-K
instead of Form 10-KSB, this would be in strict noncontravention with such
sentence because we would be changing from one category to another with respect
to reports under the Exchange Act for a single fiscal year.



         2. The research and development expenses for 2005 and 2004 amounted to
$537,795 and $309,302, respectively and are included in general and
administrative expenses. While the amounts are not disclosed in the footnotes to
the consolidated financial statements, they are disclosed in our Management
Discussion and Analysis ("M, D & A). We would like to propose that we do not
amend our December 31, 2005 Form 10-KSB but that we disclose this information in
the footnotes to the consolidated financial statements in future filings.

         3. While we did not disclose the revenues from external customers for
our plant based pharmaceutical products and our plant based nutraceutical
products in the footnotes to the consolidated financial statements, the amounts
are disclosed in our M, D & A. We would like to propose that we do not amend our
December 31, 2005 Form 10-KSB but that we disclose this information in the
footnotes to the consolidated financial statements in future filings.

Should you have any questions with respect to the foregoing, please feel free to
contact our counsel Beth Neuhaus at (212) 407-4902.

Very truly yours,

/s/ Yanchun Li
----------------------
Yanchun Li
Acting Chief Financial Officer