Sinoenergy Corporation

October 24, 2006

VIA EDGAR

Securities and Exchange Commission

Washington, DC 20549

Attention:Jason Wynn, Esq.

Re: Sinoenergy Corporation. Registration Statement on Form SB-2  File No. 333-136262                                

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), Sinoenergy Corporation (the “Company”) requests that the effective date of the registration statement referred to above be accelerated so that it will become effective at 3:00 p.m., Eastern Time, on Thursday, October 26, 2006, or as soon thereafter as possible.

We hereby acknowledge the following:

·   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.

Very truly yours,

Sinoenergy Corporation

By:  /s/ Bo Huang                              

Bo Huang

Chief Executive Officer