XINYINHAI TECHNOLOGY, LTD.

No. 16 Dalian Road, Haping Road

Centralized Industrial Park, Harbin Development Zone

P.R. China 150060

September 16, 2009

VIA EDGAR

Linda Cvrkel

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E., Washington, DC 20549

Re:	Xinyinhai Technology, Ltd.
	Form 10-K for the fiscal year ended December 31, 2008
	File No. 000-51012

Dear Ms. Cvrkel:

I am writing in response to your letter dated September 2, 2009.  We are actively preparing a response to the comment set forth in your letter.  However we will require additional time to provide a complete response.  We expect to file our response on EDGAR no later than September 28, 2009.

Yours.

/s/ Tian Ling

Tian Ling, Chief Executive Officer