Mail Stop 3561

      November 28, 2005


Via U.S. Mail and Fax
Deli Du
Chief Executive Officer
Deli Solar (USA), Inc.
558 Lime Rock Road
Lakeville, Connecticut 06039

	Re:	Deli Solar (USA), Inc.
		Form SB-2
		Filed November 2, 2005
		File No. 333-129369

Dear Mr. Du:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form SB-2

Risk Factors, page 12

Recent PRC regulations relating to acquisitions of PRC companies
by
foreign entities may create regulatory uncertainties..., page 18
1. As your risk factor heading suggests, there are certain
uncertainties that have been created by recent SAFE regulations.
Rather than focusing on how the company has complied with the
recent
regulations (which you do so in the first four paragraphs of the
risk
factor), you should focus the risk factor discussion on the
uncertainties that the October SAFE notice does not "clear up."
In
addition, the first part of the risk factor discussion should be
moved to your "Government Regulation" section of your discussion
of
your business.

Business, page 27

Government Regulation, page 45
2. Revise to make clear when you expect to obtain approval for
production of your boilers and space heating products from the
provincial level of the Quality and Technology Supervisory and
Control Bureau.

Financial Statements, page F-6
3. We note that you have identified Bazhou Deli Solar (PRC) as the
accounting acquirer in the acquisition of Bazhou Deli Solar (PRC)
by
Deli Solar (BVI).  Also we note your disclosure on page 28 that
Deli
Solar (BVI) acquired Bazhou Deli Solar (PRC) for cash.  To help us
better understand your conclusion tell us in your response to this
comment letter about the terms of the acquisition and the facts
that
support your determination that PRC is the accounting acquirer in
the
acquisition of Bazhou Deli Solar (PRC) by Deli Solar (BVI).
4. We also note that you have identified Bazhou Deli Solar (PRC)
as
the accounting acquirer in Meditech`s acquisition of Deli Solar
(BVI).  In your response letter, please provide us with more
detail
about how you came to this conclusion.
5. Please revise to include the historical financial statements of
Meditech Pharmaceuticals, Inc. in accordance with Item 310(c) of
Regulation S-B.

Signatures, page II-6
6. Revise to include the signature of the individual serving in
his
capacity as the principal accounting officer.




*	*	*	*

      As appropriate, please amend your Form SB-2 in response to
these comments.  You may wish to provide us with marked copies of
the
amendment to expedite our review.  Please file on EDGAR a cover
letter with your amendment that keys your responses to our
comments
and provides any requested information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the Company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures that
they have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the Company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they may relate to the proposed public
offering of the securities specified in the above registration
statement.  We will act on the request and, pursuant to delegated
authority, grant acceleration of the effective date.



      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Christine Bashaw, Staff Accountant, at (202)
551-3363 or Terry French, Accountant Branch Chief, at (202) 551-
3828
if you have questions regarding comments on the financial
statements
and related matters.  Please contact Derek Swanson, Staff
Attorney,
at (202) 551-3366, or me at (202) 551-3810 with any other
questions.


								Sincerely,


								/s/ Larry Spirgel
								Larry Spirgel
								Assistant Director























cc:	Darren Ofsink
	Guzov Ofsink, LLC
	Via Facsimile: (212) 688-7273
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Mr. Du
Deli Solar (USA), Inc.
November 28, 2005
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE