CORRESP

DLA Piper Rudnick Gray Cary US LLP
2000 University Avenue
East Palo Alto, California 94303-2215
O    650.833.2459
F     650.833.2001
W   www.dlapiper.com

June 6, 2006 OUR FILE NO. 359888-000002

Via Facsimile, UPS and EDGAR

Mr. William H. Demarest
Staff Accountant
Securities and Exchange Commission
100 F Street NW
Mail Stop 4561
Washington, DC 20549

Re:	Sun New Media, Inc.
	Form 8-K filed May 24, 2006
	File No. 0-26347

Dear Mr. Demarest:

We are writing on behalf of our client, Sun New Media, Inc. (the “Company”), in response to written comments from the Staff of the Securities and Exchange Commission (the “SEC”) received on June 1, 2006 with respect to the Company’s Form 8-K filed May 24, 2006. The italicized paragraphs below includes the Staff’s written comments, and the discussion set out below each such paragraph is the Company’s response to the Staff’s comments.

Form 8-K Filed May 24, 2005

1. We note that on May 18, 2006 you appointed Bernstein & Pinchuk LLP as your new independent accountants. Please have your new independent accountants explain to us in sufficient detail how they plan on performing the audit of the international operations of your company. In addition, have them tell us whether a foreign audit firm will be assisting in the audit and, is so, whether such foreign firm is credentialed with the SEC or registered with the PCAOB, if required. Lastly, if a foreign audit firm will be assisting in the audit, tell us if Bernstein & Pinchuk LLP will qualify as the principal accountant.

Attached please find a copy of the letter dated as of today’s date from Bernstein & Pinchuk LLP addressing the above request.

* * *

Mr. William H. Demarest
June 6, 2006
Page Two

Should you have any questions regarding the foregoing or require any additional information, please do not hesitate to contact the undersigned at (650) 833-2036 or Beth O’Callahan at (650) 833-2271. Thank you very much for your assistance.

Very truly yours,

DLA Piper Rudnick Gray Cary US LLP

/s/ Peter M. Astiz

Peter M. Astiz
peter.astiz@dlapiper.com

PMA:mkr

cc:	Mr. Frank Zhao, Sun New Media, Inc.
	Mr. Neil Pinchuk, Bernstein & Pinchuk, LLP

CORRESP

Bernstein & Pinchuk LLP

Certified Public Accountants

Seven Penn Plaza, Suite 830

New York, NY 10001

Tel 212 279-7900

Tel 516 897-7979

Fax 212 279-7901
www.bpaccountants.com

June 5, 2006

William H. Demarest
U.S. Securities and Exchange Commission
Washington, DC 20549

RE:	Sun New Media, Inc.
	Form 8K Filed May 24, 2006
	File No. 0-26347

Dear Mr. Demarest:

     This letter is in response to your letter dated May 25, 2006 to Sun New Media, Inc. requesting a letter from us detailing how we plan on performing the audit of the above company’s international operations.

     We have employed an individual, Mr. Xin-Hua Mao, who works in Beijing, China to assist us in performing our audit of Sun New Media’s international operations. Mr. Mao is highly qualified to perform SEC compliant audits and is individually registered with the PCAOB. Mr. Mao’s work will be subject to our collaborative planning, supervision and review. A partner of our firm, Mr. Drew Bernstein, has traveled extensively to China in the past and will spend a significant amount of time in China performing many of those supervisory and review audit procedures for this audit and several other foreign audit engagements. We also plan to have other audit personnel from our New York City office travel to China to perform audit work. We will not be relying on the work of another foreign audit firm.

     We would be happy to answer any further questions if necessary.

Very truly yours,

Neil Pinchuk