[HIGHWAY HOLDINGS LIMITED Suite No. 810, Level 8 Landmark North 39 Lung Sum Avenue Sheung Shui New Territories, Hong Kong September 27, 2005 Via EDGAR Division of Corporate Finance Office of Small Business Review 450 Fifth Street, N.W. Attn: Nili Shah—Branch Chief Re: Highway Holdings Limited File 0-28990 Dear Mr. Shah: Form 20-F for the year ended March 31, 2005]