CHINA WATER AND DRINKS, INC.

18^th Floor, Development Centre Building

Ren Min Nan Road, Shenzhen

People’s Republic of China 58001

October 17, 2007

VIA EDGAR AND FACSIMILE

Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549

Attention: Mara Ransom and Indira Lall

Re: Request for Withdrawal of Registration Statement on Form SB-2,

File Number 333-146097 (the “Registration Statement”)

Dear Ms Ransom and Ms Lall:

China Water and Drinks, Inc. (the ”Company”) hereby makes application to withdraw the Registration Statement pursuant to Rule 477 under the Securities Act of 1933, as amended (the “Securities Act”). No securities have been sold under the Registration Statement. The Company may undertake a subsequent private offering in reliance on Securities Act Rule 155(c).

Accordingly, the Company requests an order granting the withdrawal of the Registration Statement be issued by the Securities and Exchange Commission as soon as possible. Please provide a copy of the order granting withdrawal via facsimile to the Company’s counsel, Mitchell Nussbaum or Angela Dowd, at (212) 407-4990. Should you have any questions regarding this matter, please contact Ms Dowd at (212) 407-4097.

Very truly yours,

CHINA WATER AND DRINKS, INC.

By: /s/Chen Xing Hua

Chen Xing Hua

Chief Executive Officer