January 30, 2012

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington D.C. 20549-3561

Attention: Pamela A. Long

Re:	Acceleration Request of China Dredging Group Co., Ltd.
	Registration Statement on Form F-1 (File No. 333-178362)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, China Dredging Group Co., Ltd. (the “Company”) hereby requests that the United States Securities and Exchange Commission (the “Commission”) accelerate the effectiveness of the above-referenced Registration Statement,to 4:00 p.m., Eastern Time, on Tuesday, January 31, 2012, or as soon thereafter as practicable. The Company also hereby requests a copy of the written order verifying the effective date.

The Company hereby acknowledges that:

· should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

· the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

· the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Thank you for your assistance. If you should have any questions, please contact Andrew Ledbetter of DLA Piper LLP (US), counsel to the Company, at (206) 839-4845 or andrew.ledbetter@dlapiper.com.

Very truly yours,
China Dredging Group Co., Ltd.
By:	/s/ Alfred Ho
	Alfred Ho
	Chief Financial Officer