Dragon Pharmaceutical Inc.
                        1055 Hastings Street, Suite 1900
                       Vancouver, British Columbia V6E 2E9


                                      October 29, 2004

VIA EDGAR

Division of Corporate Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

     Re:   Application for Withdrawal of Registration Statement on
           Form S-4 (No. 333-117428)
           -------------------------

Dear Sir/Madam:

     Pursuant to Rule 477 of the  Securities  Act of 1933,  as  amended,  Dragon
Pharmaceutical  Inc.,  (the  "Company")  hereby  respectfully  requests that the
above-referenced  Registration  Statement be withdrawn  and that an order of the
Commission granting such withdrawal be granted.

     The withdrawal of the Registration Statement is in response to the Staff of
the  Division  of   Corporation's   comment   letter  in  connection   with  the
above-referenced  Registration Statement.  This letter will also confirm that no
shares of the  Company's  common  stock were sold  pursuant to the  Registration
Statement.  Accordingly, the Company respectfully submits that the withdrawal of
the  Registration  Statement  is  consistent  with the public  interest  and the
protection of investors.

     Should  you have any  questions  or  comments,  please do not  hesitate  to
contact Daniel B. Eng, Esq. of Bartel Eng & Schroder, a Law Corporation, counsel
to the Company, at (916) 442-0400.

                                       Very truly yours,
                                       Dragon Pharmaceutical Inc.


                                       By: /s/ Alexander Wick
                                       -----------------------------------
                                       Alexander Wick
                                       Chief Executive Officer