BEYOND GOLDEN HOLDINGS LIMITED

Akara Building

24 De Castro Street

Wickhams Cay 1

Road Town

Tortola, British Virgin Islands

August 23, 2010

Division of Corporation Finance

Securities and Exchange Commission

100 F Street

Washington, DC 20549

    Re:      Beyond Golden Holdings Limited

Form 20-F

Filed June 25, 2010

File No. 000-54021

Ladies and Gentlemen:

Beyond Golden Holdings Limited, pursuant to Rule 477, hereby requests that the Securities and Exchange Commission consent to the withdrawal of the Company’s registration statement on Form 20-F (File No. 000-54021).  We are requesting withdrawal of the registration statement to permit us to resolve certain disclosure issues raised by the Staff of the Securities and Exchange Commission prior to the effectiveness of the registration statement.  We intend to submit a new registration statement with appropriate revisions.

If you have any questions or require further information regarding this application, please contact our counsel, Robert Brantl, at 914-693-3026.

Sincerely,
	/s/ Wei Guo
	Wei Guo
	Chief Executive Officer