DALIAN CAPITAL GROUP, INC.
Suite 900, 850 West Hastings Street.
Vancouver, BC V6C 1E1
Tel : 604-801-5022   Fax : 604-876-5564


January 5, 2010

United States
Securities and Exchange Commission
Washington, D.C 20549

Attention : Brian Bhandari or Raj Rajan or Tia Jenkins.

File No. 000-52185

Dear M/s Tia Jenkins,

Re : Form 10-K for Fiscal Year Ended December 31, 2008

Item 9A Controls and Procedures (will be amended as
follows)

As supervised by our board of directors and our principal
executive and principal financial officers, management has
established a system of disclosure controls and procedures
and has evaluated the effectiveness of that system.  The
system and its evaluation are reported on in the below
Management's Annual Report on Internal Control over
Financial Reporting.  Our principal executive and financial
officer has concluded that our disclosure controls and
procedures (as defined in the 1934 Securities Exchange Act
Rule 13a-15(e)) as of December 31, 2008, are not effective,
based on the evaluation of these controls and procedures
required by paragraph (b) of Rule 13a-15. There is a
material weakness in the registrant's internal control over
financial reporting as error was reported that 2,000 shares
of common stock at $0.15 per shares were issued on November
21, 2008, when actually none were issued. The management
has made changes in internal control over financial
reporting that reconciliation of shares with the Transfer
Agent's list to be carried out at every period or year end.

Management's Annual Report on Internal Control over
Financial Reporting

Management is responsible for establishing and maintaining
adequate internal control over financial reporting, as such
term is defined in Rule 13a-15(f) of the Securities
Exchange Act of 1934 (the "Exchange Act").  Internal
control over financial reporting is a process designed to
provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial
statements for external purposes in accordance with U.S.
generally accepted accounting principles.

Management has re-assessed the effectiveness of internal
control over financial reporting as of December 31, 2008.
We carried out this re-assessment using the criteria of the
Committee of Sponsoring Organizations of the Treadway
Commission (COSO) in Internal Control-Integrated Framework.


This annual report does not include an attestation report
of our registered public accounting firm regarding internal
control over financial reporting.  Management's report was
not subject to attestation by our registered public
accounting firm, pursuant to temporary rules of the
Securities and Exchange Commission that permit us to
provide only management's report in this annual report.
Management concluded in this assessment that as of December
31, 2008, our internal control over financial reporting is
effective.
There have been changes in our internal control over
financial reporting (as defined in Rules 13a-15(f) and 15d-
15(f) under the Exchange Act) during the fourth quarter of
our 2008 fiscal year that have materially affected, or are
reasonably likely to materially affect, our internal
control over financial reporting.

Re : Form 10-Q for the Quarter Ended June 30, 2009 and Form
10-Q for the Quarter Ended September 30, 2009.

Item 4T. Controls and Procedures (will be amended as
follows)

The Company's Chief Executive Officer and its Chief
Financial Officer are primarily responsible for the
accuracy of the financial information that is presented in
this Quarterly Report. These officers have as of the close
of the period covered by this Quarterly Report, evaluated
the Company's disclosure controls and procedures (as
defined in Rules 13a-4c and 15d-14c) promulgated under the
Securities Exchange Act of 1934 and determined that such
controls and procedure were not effective in ensuring that
material information relating to the Company was made known
to them during the period covered by this Quarterly Report.

There have been changes in our internal control over
financial reporting (as defined in Rules 13a-15(f) and 15d-
15(f) under the Exchange Act) during the fourth quarter of
our 2008 fiscal year that have materially affected, or
reasonably likely to materially affect, our internal
control over financial reporting.

Please advise us whether the above amendments are agreeable
to you and appreciate your comments.

We will file amend to include in plain text and will file a
Form 10-K/A and a Form 10-Q/A for the periods ended June
30, 2009 and September 30, 3009 within 10 days after
receiving a reply to our letter.

Thanking you in advance.

Yours truly,

/s/ Michael Lee
 Michael Lee
Chief Accounting Officer