XNY [China Xiniya Fashion] CORRESP: (Original Filing)

[November 19, 2010 Mr. Damon Colbert Re: China Xiniya Fashion Limited Dear Mr. Colbert: In connection with the above-captioned Registration Statement, we wish to advise that between November 8, 2010 and the date hereof 3600 copies of the Preliminary Prospectus dated November 8, 2010 were distributed as follows: 3600 to 4 underwriters; 1900 institutional investors; 450 individuals. * * *]

XNY [China Xiniya Fashion] CORRESP: November 19, 2010 Mr. Damon Colbert Re: China

[November 19, 2010 Mr. Damon Colbert Re: China Xiniya Fashion Limited Dear Mr. Colbert: In connection with the above-captioned Registration Statement, we wish to advise that between November 8, 2010 and the date hereof 3600 copies of the Preliminary Prospectus dated November 8, 2010 were distributed as follows: 3600 to 4 underwriters; 1900 institutional investors; 450 individuals. * * *]

XNY [China Xiniya Fashion] CORRESP: (Original Filing)

[China Xiniya Fashion Limited November 19, 2010 VIA FACSIMILE AND EDGAR China Xiniya Fashion Limited Registration Statement on Form F-1 Ladies and Gentlemen: * * * * * China Xiniya Fashion Limited Very truly yours, Chee Jiong Ng Chief Financial Officer CORRESP 1 filename1.htm]

XNY [China Xiniya Fashion] CORRESP: China Xiniya Fashion Limited November 19, 2010 VIA

[China Xiniya Fashion Limited November 19, 2010 VIA FACSIMILE AND EDGAR China Xiniya Fashion Limited Registration Statement on Form F-1 Ladies and Gentlemen: * * * * * China Xiniya Fashion Limited Very truly yours, Chee Jiong Ng Chief Financial Officer CORRESP 1 filename1.htm]

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