[HIGHWAY HOLDINGS LIMITED Landmark North, Suite 1801, Level 18 39 Lung Sum Avenue Sheung Shui New Territories, Hong Kong February 7, 2012 Via EDGAR John Cash Accounting Branch Chief Division of Corporation Finance 100 F Street, N.E. Re: Highway Holdings Limited Form 20-F for the Fiscal Year Ended March 31, 2011 Filed June 29, 2011 File No. 0-28990 Dear Mr.]