April 27, 2006

Mail Stop 4561

Lin, Chin-Jung
Principal Executive Officer & Director
Sunrise Real Estate Development Group, Inc.
Suite 701, No. 333 Zhaojiabang Road
Shanghai, China PRC

	RE:	Sunrise Real Estate Development Group, Inc.
		Information Statement on Schedule 14C
		File No. 0-32585
		Filed April 18, 2006

Dear Mr. Lin:

      This is to advise you that we have limited our review of the
above referenced information statement to the following comment.
Where indicated, we think you should revise your document in
response
to this comment.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanation.  We may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

   	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

1. Please revise to provide the information required by Item 6(d)
of
Schedule 14A.

      As appropriate, please revise your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the revisions to expedite our review.  Please furnish a cover
letter
with your revised document that keys your response to our comment
and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your revised document and responses to
our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	Please direct any questions to Charito A. Mittelman at (202)
551-3402, or the undersigned at (202) 551-3694.

      Sincerely,



Owen Pinkerton
Senior Counsel

cc: 	Carl A. Generes, Esq.  (via facsimile)


Lin, Chin-Jung
Sunrise Real Estate Development Group, Inc.
April 27, 2006
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