RUB A DUB SOAP, INC.
                           No. 177, Chengyang Section
                              308 National Highway
                             Danshan Industrial Area
                              Qingdao, China 200109


                                                              June 2, 2008


By EDGAR Transmission and by Hand Delivery
- ------------------------------------------

John Cash
Mindy Hooker
Tricia Armelin
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E., Mail Stop 4561
Washington, D.C. 20549


         RE:      Rub A Dub Soap, Inc.
                  Form 8-K filed November 14, 2007
                  File No. 0-52142


Dear Mr. Cash:

         On behalf of Rub A Dub Soap,  Inc.  ("RUBD" or the  "Company"),  we are
providing the following  responses to comments of the Staff (the "Staff") of the
Securities and Exchange Commission  contained in the letter from the Staff dated
May 15, 2008 ("Comment  Letter")  regarding the  above-referenced  Form 8-K (the
"Form 8-K").

         Set forth below are the Company's responses to the Staff's comments. To
assist your review,  we have retyped the text of the Staff's comments in italics
below.

General
- -------

1.   We note your  response to our prior comment one from our letter dated March
     17, 2008 and your related  disclosure  on page 17 of your Form 10-Q for the
     period ended March 31, 2008 that the acquired  subsidiaries  operate  under
     common  control  because  they all have  the same key  management  members.
     Please  confirm  for us,  if true,  that the  voting  ownership  meets  the
     criteria for common control in all financial periods presented prior to the
     August 2007 acquisitions. Reference paragraph 3 of EITF 02-5.

Response:

         The Company hereby  confirms that the voting  ownership of the acquired
subsidiaries  meets the criteria  for common  control in all  financial  periods
presented prior to the August 2007 acquisitions for the following reasons:




John Cash
Page 2 of 2
May 30, 2008

         Pursuant to paragraph 3 of EITF No. 02-5,  common  control exists among
separate  entities if immediate  family members hold more than 50% of the voting
ownership  interest of each entity.  Immediate  family members include a married
couple. As explained below, prior to the August 2007 acquisitions,  our CEO, Mr.
Long Qin,  together  with his  wife,  Ms.  Xiuqin Li owned  more than 50% of the
voting ownership interest of each acquired subsidiary.

         The acquired  subsidiaries  include Qingdao  Free-Trading Zone Sentaida
International  Trade Co., Ltd.,  ("FTZ  Sentaida"),  Qingdao Sentaida Tires Co.,
Ltd. ("Sentaida Tires"), and Zhongsen Holdings Co., Ltd. ("Zhongsen  Holdings").
Prior  to the  acquisitions  of these  subsidiaries  by  Zhongsen  International
Company  Group Limited in 2007,  Mr. Qin owned 100% equity  interest in Zhongsen
Holdings.  Sentaida  Group Ltd., in which Mr. Qin owned 76%  interest,  held 51%
equity  interest  in both  FTZ  Sentaida  and  Sentaida  Tires.  Thus,  Mr.  Qin
indirectly  owned  38.76% (76% x 51%) equity  interest in both FTZ  Sentaida and
Sentaida Tires.  Mr. Qin's wife, Ms. Li owned 37.24% equity interest in both FTZ
Sentaida and Sentaida Tires.  As a result,  Mr. Qin together with his wife owned
100%,  76%  (38.76% + 37.24%),  and 76%  (38.76% + 37.24%)  equity  interest  in
Zhongsen Holdings, FTZ Sentaida, and Sentaida Tires, respectively.

         Therefore,  prior to the August  2007  acquisitions,  all the  acquired
subsidiaries  operated under common control  pursuant to paragraph 3 of EITF No.
02-5.

         If you  would  like to  discuss  the Form 8-K or if you  would  like to
discuss any other matters, please contact Scott Kline, Esq. of Thelen Reid Brown
Raysman & Steiner LLP, our outside special securities counsel at (415) 369-7166.


                                           Sincerely,

                                           RUB A DUB SOAP, INC.


                                           By: /s/ Long Qin
                                           -------------------------------------
                                           Long Qin
                                           President and Chief Executive Officer






CC:      Scott Kline, Esq.
         (415) 369-7166