United States securities and exchange commission logo





                            August 27, 2020

       Yuantong Wang
       President and Chief Executive Officer
       Adaiah Distribution, Inc.
       Tianan Technology Park
       13/F Headquarters Center Building 16
       555 Panyu North Ave, Panyu District, Guangzhou City, China

                                                        Re: Adaiah Distribution
Inc.
                                                            Form 8-K
                                                            Filed August 20,
2020
                                                            File No. 000-55369

       Dear Mr. Wang:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 8-K filed August 20, 2020

       General

   1.                                                   It appears that
immediately before the transaction with Guangzhou Huaizhong Health
                                                        Technology Co., Ltd.,
you were a shell company, as defined in Rule 12b-2 under the
                                                        Securities Exchange Act
of 1934, as amended. Accordingly, please amend your report to
                                                        provide the information
required by Item 2.01(f) of Form 8-K and the related financial
                                                        information required by
Item 9.01 of Form 8-K, or provide us with a detailed analysis of
                                                        why this disclosure is
not required.
               We remind you that the company and its management are
responsible for the accuracy
       and adequacy of their disclosures, notwithstanding any review, comments,
action or absence of
       action by the staff.
 Yuantong Wang
Adaiah Distribution, Inc.
August 27, 2020
Page 2

      Please contact Matthew Crispino, Staff Attorney, at (202) 551-3456 or Jan
Woo, Legal
Branch Chief, at (202) 551-3453 with any questions.



                                                         Sincerely,
FirstName LastNameYuantong Wang
                                                         Division of
Corporation Finance
Comapany NameAdaiah Distribution, Inc.
                                                         Office of Technology
August 27, 2020 Page 2
cc:       Richard I. Anslow
FirstName LastName