Mail Stop 0407


									August 2, 2005
Via U.S. Mail and Fax c/o Kevin Leung, Esq. (310-208-1154)
Mr. Yau-Sing Tang
President and Chief Financial Officer
China Cable and Communications, Inc.
22 Bei Xin Cun Hou Street, Xiang Shan, Haidian District
Beijing 100093, the People`s Republic of China

	RE:	China Cable and Communications, Inc.
      Form 10-KSB for the fiscal year ended December 31, 2004
		Filed May 16, 2005


Dear Mr. Yau-Sing Tang:

      We have reviewed your supplemental response letter dated
June
22, 2005 as well as the above referenced filings and have the
following comments.  As noted in our comment letter dated June 10,
1005, we have limited our review to only the issues addressed in
our
letter and will make no further review of your documents.  As
such,
all persons who are responsible for the adequacy and accuracy of
the
disclosure are urged to be certain that they have included all
information required pursuant to the Securities Exchange Act of
1934.

	Form 10-KSB for the fiscal year ended December 31, 2004

	Summary of Significant Accounting Policies
	General, page F-9

1. We note your response to our prior comment number 4.  As
defined
in Rule 4-08(e)(3) of Regulation S-X, restricted net assets
include
that amount of the registrant`s proportionate share of net assets
reflected in the balance sheet of its consolidated and
unconsolidated
subsidiaries which may not be transferred to the parent company in
the form of loans, advances or cash dividends by the subsidiaries
without the consent of a third party.  We note in your response to
our prior comment #1 that your expected cash dividend from the
Baoding joint venture is contingent upon approval by the State
Administration of Foreign Exchange and by the local People`s
Republic
of China tax bureau, which would appear to meet the definition of
a
restricted net asset.  Please disclose if there are any assets on
your consolidated balance sheet that are not transferable to you
without the consent of a third party.  If so, please comply with
the
disclosure required by Rule 4-08(e)(3) of Regulation S-X.

Basis of Consolidation, page F-9

2. We note your response to our prior comment number 5.  We also
note
from the risk factors in your Form 10-KSB for the period ended
December 31, 2004 that you are dependent on funding through
dividend
distribution from the joint venture.  This dependency is also
noted
in your response to our prior comment number 1.  Exhibit 96-16A(3)
of
EITF 96-16 states rights to block customary or expected dividends
or
other distributions may be substantive participating rights.
Please
tell us why the control over your primary source of funding would
not
be considered substantive participating rights.

Impairment, page F-11

3. We note your response to our prior comment #6.  Please tell us
specifically and provide the quantitative analysis showing how you
determined there was no impairment of your long-lived assets given
your historical financial results and current going concern
status.

Form 10-QSB for the period ended March 31, 2005

Financial Condition, Liquidity, Capital Resources
Plan of Operation, page 26

4. We note your Plan of Operation on page 26 states that you
expect
to receive a cash dividend from the Baoding joint venture, subject
to
certain contingencies and on page 27 you state that you will
receive
the cash dividend.  Please amend your Form 10-Q to clarify the
status
of the cash dividend as of the reporting date.


*    *    *    *

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response on EDGAR.  You may contact Bob Carroll, Staff Accountant,
at
(202) 551-3362 or Carlos Pacho, Senior Assistant Chief Accountant,
at
(202) 551-3835 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
551-3810 if you have any other questions.

							Sincerely,

							/s/ Kyle Moffatt for

							Larry Spirgel
							Assistant Director


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Mr. Yau-Sing Tang
China Cable and Communications
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE