February 10, 2006


By facsimile to (214) 659-4401 and U.S. Mail


Mr. Xiangqian Li
Chairman, President, and Chief Executive Officer
China BAK Battery, Inc.
BAK Industrial Park
No. 1 BAK Street
Kuichong Town, Longgang District
Shenzhen, People`s Republic of China

RE:	China BAK Battery, Inc.
	Pre-effective Amendment 1 to Registration Statement on Form
SB-2
	Filed February 3, 2005
File No. 333-130247

Dear Mr. Li:

      We reviewed the filing and have the comments below.

1. If applicable, comments on this registration statement are
comments on the registration statement on Form SB-2 that was filed
on
January 21, 2005, the annual report on Form 10-KSB that was filed
on
December 30, 2005, and subsequent reports under the Exchange Act
and
vice versa.

Selling Stockholders, page 43

2. Refer to prior comments 2 and 3.  Expand the disclosures in
footnotes (10), (20), and (23) to describe briefly how the selling
stockholders acquired the securities "prior to the consummation of
the private placement on September 16, 2005" that are being
offered
for resale.

3. We are unable to locate the response to prior comment 4.  Thus,
we
reissue the comment to disclose how China BAK Battery will use the
proceeds that it will receive upon the warrants` exercise.
4. Refer to prior comment 7.  As requested previously, clarify in
footnotes (7) and (12) whether Messrs. David Hokin and Alec
Litowitz
have sole or shared voting and investment control over the
securities.  If Messrs. Hokin and Litowitz share voting and
investment control, identify the natural person or persons with
whom
each shares the control.

Closing

	File an amendment to the SB-2 in response to the comments.
To
expedite our review, China BAK Battery may wish to provide us
three
marked courtesy copies of the amendments.  Include with the
filings
any supplemental information requested and a cover letter tagged
as
correspondence that keys the responses to the comments.  If China
BAK
Battery thinks that compliance with any of the comments is
inappropriate, provide the basis in the letter.  We may have
additional comments after review of the amendments, the responses
to
the comments, and any supplemental information.

	We urge all persons responsible for the accuracy and adequacy
of
the disclosure in the registration statement reviewed by us to
ensure
that they have provided all information investors require for an
informed decision.  Since China BAK Battery and its management are
in
possession of all facts relating to the disclosure in the
registration statement, they are responsible for the adequacy and
accuracy of the disclosures that they have made.

      If China BAK Battery requests acceleration of the
registration
statement`s effectiveness, China BAK Battery should furnish a
letter
at the time of the request, acknowledging that:

* Should the Commission or the staff acting by delegated authority
declare the registration statement effective, it does not
foreclose
the Commission from taking any action on the filing.

* The action of the Commission or the staff acting by delegated
authority in declaring the registration statement effective does
not
relieve China BAK Battery from its full responsibility for the
adequacy and accuracy of the registration statement`s disclosures.

* China BAK Battery may not assert our comments or the declaration
of
the registration statement`s effectiveness as a defense in any
proceedings initiated by the Commission or any person under the
United States` federal securities laws.

	The Commission`s Division of Enforcement has access to all
information that China BAK Battery provides us in our review of
the
registration statement or in response to our comments on the
registration statement.

	We will consider a written request for acceleration of the
registration statement`s effectiveness under Rule 461 of
Regulation C
under the Securities Act as confirmation that those requesting
acceleration are aware of their responsibilities under the
Securities
Act and the Exchange Act as they relate to the proposed public
offering of the securities specified in the registration
statement.
We will act on the request and by delegated authority grant
acceleration of the registration statement`s effectiveness.

	You may direct questions on comments and disclosure issues to
Edward M. Kelly, Senior Counsel, at (202) 551-3728 or me at (202)
551-3767.

Very truly yours,





Jennifer R. Hardy

Legal
Branch Chief

cc:	Nevada Agency and Trust Company
	Agent for Service, China BAK Battery, Inc., f/k/a Medina
Coffee,
Inc.
	50 West Liberty Street, Suite 880
	Reno, NV 89501

	Robin Bradford, Esq.
	Andrews Kurth LLP
	1717 Main Street, Suite 3700
	Dallas, TX 75201



Mr. Xiangqian Li
February 10, 2006
Page 1








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

         DIVISION OF
CORPORATION FINANCE