MAIL STOP 3561

      March 28, 2006

Rudy Wilson, Chief Executive Officer
Asia Automotive Acquisition Corporation
401 South Old Woodward, Ste. 450
Birmingham, MI 48009

      Re:	Asia Automotive Acquisition Corporation
   Amendment No. 4 to Registration Statement on
   Form S-1
   Filed March 10, 2006
   File No. 333-127755

Dear Mr. Wilson,

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


Summary

1. Clarify, if true, that the 19.99% will not be changed.

Proposed Business, page 28

2. We reissue comment 10 of our letter dated March 6, 2006.
Please
provide a complete citation to the source of the information for
each
bulleted point on page 28.  For example, please provide a citation
that would allow investors to find this information, such as the
name
of the article and date of the publication or a website address.
We
continue to note the reference to Internal Assessment.  If this is
the internal assessment of management, please provide the basis
for
the internal assessment.  We may have further comment.

3. When dealing with "target clients" please revise to discuss the
obligations of Asia Development Capital and your officers and
directors to both the clients and you.

4. We note the additional disclosure that Asia Development Capital
will not receive compensation from you or their client for
introductions to you.  Are they not already receiving compensation
from their clients?  If so, the introduction would only be a part
of
the services they would provide to their client and aid in
retaining
such client.  Please revise your disclosure to reflect the
economic
realities involved with their ability to use you as a part of
their
main business operations.

5. We note your response to comment 11 of our letter dated March
6,
2006.  It is not clear how the analysis of components or
subsystems
will aid in the determination to pursue a certain target client.
Are
some components or subsystems more attractive than others?  If so,
explain why.

Principal Stockholders, page 43

6. We note the control persons for Asia Development Capital LLC.
The
shares owned by Asia Development should be included in the
beneficial
ownership table for each control person.  Please revise the table
accordingly.

Certain Transactions, page 45

7. We note your response to comment 18 of our letter dated March
6,
2006.  Please advise supplementally how the sale of shares to the
Globis entities was consistent with the federal securities laws.


Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Carlton Tartar (202) 551-3387 if you have
questions regarding comments on the financial statements and
related
matters.  Questions on other disclosure issues may be directed to
Duc
Dang at (202) 551-3386.

						Sincerely,



						John Reynolds
      Assistant Director

Cc:  	Paul Kavanaugh
	Fax #  248-645-2690

Rudy Wilson, Chief Executive Officer
Asia Automotive Acquisition Corporation
March 28, 2006
Page 1