[September 14, 2011 Mr. Terence OBrien Accounting Branch Chief Division of Corporation Finance Re: Xinyuan Real Estate Co., Ltd. File No. 1-33863 Form 20-F for the Fiscal Year Ended December 31, 2010 Filed April 20, 2011 Dear Mr. OBrien: We have addressed each of the Staffs comments in the order presented in the Comment Letter. For ease of reference, we]
[None (Title of Class) None (Title of Class) Indicate the number of outstanding shares of each of the Issuer’s classes of capital or common stock as of the close of the period covered by the annual report. 204,375,226 ordinary shares, par value $0.0001 per share, as of December 31, 2010. [ ] [X] Yes [ ] [X] Yes [X] [] [Wuxi Seamless Oil Pipe Co., Ltd. (As Borrower) Bank of China Limited Jiangsu Branch (As Arranging Bank) Bank of China Limited Wuxi Branch Agricultural Bank of China Limited Wuxi Branch (As Co-lead Bank) Bank of China Limited Wuxi Branch Agricultural Bank of China Limited Wuxi Branch Nanyang Commercial Bank (China) Limited Wuxi Branch China Merchants Bank Co., Ltd. Wuxi Branch] [Name of Subsidiaries Place of Incorporation 1. First Space Holdings Limited British Virgin Islands 2. Wuxi Seamless Oil Pipes Co. Ltd. PRC 3. Liaoyang Seamless Oil Pipes Co. Ltd. PRC 4. Houston OCTG Group, Inc. 5. Mengfeng Special Steel Co. Ltd. PRC 6. Bazhou Seamless Oil Pipes Co. Ltd. PRC 7. Songyuan Seamless Oil Pipes Co. Ltd. PRC 8. Chaoyang] [Certification by the Chief Executive Officer I, Longhua Piao, certify that: 1. 2. 3. 4. (a) (b) (c) (d) 5. (a) (b) EX-12.1 8 d28278_ex12-1.htm EX-12.1] [Certification by the Chief Financial Officer I, Choon-Hoi Then, certify that: 1. 2. 3. 4. (a) (b) (c) (d) 5. (a) (b) EX-12.2 9 d28278_ex12-2.htm EX-12.2] [Certification by the Chief Executive Officer (1) (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. EX-13.1 10 d28278_ex13-1.htm EX-13.1] [Certification by the Chief Financial Officer (1) (2) The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company. Choon-Hoi Then EX-13.2 11 d28278_ex13-2.htm EX-13.2] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the incorporation by reference in the Registration Statement No. 333-153582 on Form S-8 of our reports dated September 14, 2011, relating to the consolidated financial statements and financial statement schedule of WSP Holdings Limited and its subsidiaries (collectively, the “Company”) (which report expresses an unqualified opinion and includes an explanatory]
