[STUBBS ALDERTON & MARKILES LLP LETTERHEAD]

                                             JOSEPH STUBBS
                                             Partner
                                             Direct
                                             Voice        818.444.4507
                                             Direct Fax   818.474.8607
                                             Mobile       626.926.6018
                                             E-Mail       jstubbs@biztechlaw.com


December 9, 2004

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549-1004

         RE:      KIWA BIO-TECH PRODUCTS GROUP CORPORATION
                  RESPONSES TO STAFF COMMENTS OF DECEMBER 7, 2004
                  WITH RESPECT TO:
                  AMENDMENT NO. 2 TO REGISTRATION STATEMENT ON FORM SB-2
                  FILE NO. 333-117868, FILED NOVEMBER 23, 2004

Ladies and Gentlemen:

         On behalf of Kiwa Bio-Tech  Products Group Corporation (the "COMPANY"),
we hereby provide supplementally the following responses in reply to the Staff's
comment  letter,  dated  December 7, 2004 (the  "COMMENT  LETTER").  The factual
information  provided  herein relating to the Company has been made available to
us by the Company.  Paragraph numbering used for each supplemental  response set
forth below corresponds to the numbering used in the Comment Letter.

FORM SB-2

EMPLOYMENT AGREEMENTS, PAGE 49

         1.       WE NOTE YOUR RESPONSE TO COMMENT 28 AND REISSUE THE COMMENT IN
PART.  PLEASE DESCRIBE ANY RESTRICTIVE  COVENANTS AND OBLIGATIONS  UNDER EACH OF
THE AGREEMENTS YOU DESCRIBE IN THIS SECTION.

         In  response  to  the  Staff  prior  comments,   the  Company  included
descriptions of the material terms and employment agreements between the Company
and each of Lian-jun  Luo and Qu Bin in the  Executive  Compensation  section of
Amendment No. 2 to the SB-2  Registration  Statement.  In addition,  the Company
filed copies of the employment  agreements as Exhibit 10.13 and Exhibit 10.14 to
Amendment No. 2 to the SB-2.

         The Company  believes that all material  terms and  obligations  of the
Company under the employment  agreements have been disclosed in Amendment No. 2.
The


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Securities and Exchange Commission
December 9, 2004
Page 2


included  disclosures  describe  the term of the  agreements,  compensation  and
severance  payment  obligations.  There  are  no  other  material  covenants  or
obligations of the Company under either of these employment agreements.

         We  supplementally  note  that  each of the  employment  agreements  do
contain  covenants  of  the  employee  which  are  standard  and  customary  for
employment  agreements.  These  covenants  include a  covenant  on behalf of the
employee  not to compete  with the  Company or solicit the  Company's  employees
during the term of employment and covenants of confidentiality and nondisclosure
of Company proprietary  information.  The Company  respectfully  asserts that no
further disclosure in the SB-2 Registration  Statement is necessary with respect
to the  employment  agreements at this time.  However,  the Company will include
disclosure of these employee covenants contained in the employment  agreement in
the next Prospectus Supplement or Post-Effect Amendment to the SB-2 Registration
Statement.




         We hope the above has been responsive to the Staff's  comments.  If you
have any questions or require any additional  information  or documents,  please
telephone me at (818) 444-4507.

                                                     Sincerely,

                                                     /s/ V. Joseph Stubbs
                                                     ---------------------------
                                                     V. Joseph Stubbs

Enclosures
cc:      James Zhan