China Oumei Real Estate Inc.

Floor 28, Block C, Longhai Mingzhu Building

No. 182 Haier Road, Qingdao 266000

People’s Republic of China

Tel: (86) 532 8099 7969

June 1, 2011

By EDGAR Transmission

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attn: Duc Dang

Re:	China Oumei Real Estate Inc.

Amendment No. 9 to Registration Statement on Form S-1

Filed April 15, 2011

File No. 333-166658

We hereby submit the responses of China Oumei Real Estate Inc. (the “Company”) to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated May 2, 2011, providing the Staff’s comments with respect to the above referenced registration statement on Form S-1 (the “Registration Statement”).

For the convenience of the Staff, each of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise, references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

General

We note your response to comment 4 of our letter dated April 11, 2011, and the supplemental materials you provided on April 18, 2011. Please note that the material provided does not appear to support all of the quantitative and qualitative business and industry disclosure included in the registration statement. As such, please ensure that you provide support for all noted disclosure included in this document. For example only, please note the following:

The information in Tab C does not appear to support your disclosure on pages 33 and 59 that "CAGR from 2003 to 2009 for GFA completed was 22.4%."

In Tabs D and E, the first number in the relevant disclosure has been concealed by the sequence number, so it is not clear that the number supports your disclosure.

Additionally, we note that you have made further revisions to your disclosure. For example only, we note the revised figures in the last paragraph on page 33. Please provide updated support for your revised disclosure. Clearly mark the specific language in the supporting materials that supports each statement. Further, please tell us if any of the supporting materials were prepared specifically for you in connection with this offering.

Company Response: We respectively advise Staff that we have previously provided in prior responses supporting materials for all quantitative and qualitative business and industry disclosure included in the Registration Statement. With respect to our response letter, dated April 15, 2011, we only provided supporting materials for disclosures that were updated (in accordance with Staff’s letter dated April 11, 2011) and for additional updates reflected in Amendment No. 9. All other supporting materials were previously provided. With respect to the information noted above:

We respectively note that Tab C does indeed support our disclosure, however, the English translation was unintentionally omitted for that supporting data. We are including in Annex 1 herewith the revised Tab C with the English translation.

We are attaching herewith as Annex 1 the clean copies of Tabs D and E showing the numbers. We respectively advise Staff that such information is also available at the websites noted at the bottom of each page, as well as in the Company’s calculations that were previously provided.

With respect to page 33, we respectively advise staff that these couple changes were to conform to the corresponding disclosures found on page 60. We have previously provided the supporting materials for the data in the table on page 60 (see Tab 25 of the source material binder provided in connection with our response letter, dated August 2, 2010). The changes on page 60 to the CAGR column were solely to correct a mathematical error in the calculation of the CAGR’s. The actual source data has not been updated. As we have previously stated, none of the supporting materials were prepared specifically for us in connection with this offering.

Business, page 50

2.	We note your response to comment 5 of our letter dated April 11, 2011. We were not able to locate your revisions and therefore reissue our comment. The disclosure on page 58 does not reference 2010 as you have indicated.

Company Response: We have corrected the omission and revised the disclosure to state that “The official GDP per capita data for 2010 is not yet available as of the date of this prospectus.”

Projects in Planning, page 65

We note your response to comment 6 of our letter dated April 11, 2011. Please revise your disclosure to address how the duration of the project impacts each project's cost. Please disclose the additional costs that will impact your profit margin and clarify that these amounts are not accounted for in the table. Additionally, please revise your disclosure to identify the sources you use to determine sales prices. Further, please provide a column denoting the costs applicable to each project and clarify which costs are established and which are estimates.

Company Response: We have revised the table and added a column denoting the cost of sales applicable to each project. We also added footnotes to the table to address each of the Staff’s requests.

We note your response to comment 6 that a basis for your price projection for the Longhai Hotel project is the starting asking price for a comparable hotel. It is not clear how the asking price from another seller is an appropriate basis for your price projections. Please revise to clarify whether you are basing the price projections used in this subsection on actual comparable completed transactions.

Company Response: Unlike residential apartments, comparable sales of brand new luxury hotels, especially in the same beach front trade area as the Longhai Hotel project, are scarce due to the uniqueness of the product type. Therefore, we believe that the listing price of the only concurrent comparable property in the same trade area, although not fully indicative of the price we can achieve, is a relevant and important point of reference. Please also note that this particular sample was only one of the data points we used in estimating our selling price, along with actual sales data of similar properties in other, similar localities provided to us by experienced commercial real estate brokers and through our research on reputable real estate brokerage websites. We arrived at a comparable unit price range of 35,000 RMB – 50,000 RMB (approximately $5,350 - $7,650) per square meter after aggregating the data collected, which serves the basis for our unit price projection of $5,000 per square meter.

Projects Under Construction, page 68

We note that you expect the gross profit margin for Weihai International Plaza to increase by 11% upon completion. To the extent the estimated gross profit margin is substantially different from the actual margin as of December 25, 2010 please include a footnote to clarify the basis for the deviation.

Company Response: We have added the following footnote below the table:

“The gross profit margin for each project is subject to fluctuation during the development and selling periods, due to various factors such as general trends in selling prices discussed above, promotional campaigns in certain stages of the selling process, unit price variances caused by different design features from unit to unit and various selling schedules for different types of units in different stages of the development but within the same project.”

In the particular case of Weihai International Plaza, several factors contributed to the difference between the actual gross profit margin realized to date and the estimated gross profit margin for the entire project. In the early stage of the selling period, we launched a promotional campaign and offered significant discounts to several “block buyers” who purchased multiple units. Additionally, the majority of the units with higher-end design features, and thus higher unit prices, still remain to be constructed or sold as of the end of the reported period.

Completed Projects, page 69

6.	We note that you have provided disclosure regarding your gross profit margin. Considering these projects have been completed, please advise why you have not provided disclosure regarding your net profits.

Company Response: The costs used to calculate net profits are selling, general and administrative expenses, income taxes and other non-project-specific costs, which are not included in the cost of sales estimations. Due to the non-project-specific nature of many of these costs, it is impractical to perform an accurate computation of their allocation to each individual project and an accurate net profit disclosure for each project.

Exhibits

We note your response to comment 10 of our letter dated April 11, 2011. We note that the legal opinions are no longer relying on the Deheng Law Firm and that you have not filed a legal opinion from this law firm. Please explain the purpose for providing the consent of the Deheng Law Firm. Please refer to Section 7(a) and Rule 436 of the Securities Act. For further guidance, refer to Question 141.02 under the Division's Compliance and Disclosure Interpretations for the Securities Act. If you are relying on the Deheng Law Firm for its legal opinion, please file this opinion as an exhibit.

Company Response: We have removed the consent of Deheng Law Firm from our exhibit list.

If you would like to discuss any of the responses to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at (86) 532 8099 7969 or Louis A. Bevilacqua, Esq. of Pillsbury Winthrop Shaw Pittman LLP, our outside special securities counsel at (202) 663-8158.

	Sincerely,

	China Oumei Real Estate Inc.

	By:	/s/ Weiqing Zhang
		Weiqing Zhang
		Chief Executive Officer

ANNEX 1