CORRESP 1 filename1.htm

corresp

November 19, 2010

Mr. Damon Colbert
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

Re: China Xiniya Fashion Limited
Registration Statement Filed on Form F-1
Registration No. 333-170368

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.

     We have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934.

     We hereby join in the request of the registrant that the effectiveness of the above-captioned Registration Statement, as amended, be accelerated at 4:00 p.m. (New York time) on November 22, 2010 or as soon thereafter as practicable.

* * * * * * * *

COWEN AND COMPANY, LLC
as Representative to the several Underwriters

By: /s/ Kevin Raidy                
Name: Kevin Raidy
Title: Managing Director, Co-Head of Equity Capital Markets