Unit 1502, 15th Floor
                                 Worldwide House
                      19 Des Voeux Road Central, Hong Kong

October 28, 2003

Michael Ferraro
Securities and Exchange Commission
Mail Stop 0304
450 Fifth Street, N.W.
Washington, D.C. 20549
Dear Mr. Ferraro:

RE:      Apex Wealth Enterprises Limited
         Registration Statement on Form F-1:
         File No. 333-108930

     Apex  Wealth  Enterprises  Limited  (the  "Company")  hereby  notifies  the
Securities   and   Exchange   Commission   of  its   decision  to  withdraw  the
above-referenced  Form F-1  Registration  Statement  and requests  that an order
consenting to the withdrawal be entered effective immediately.

     The Company  filed the  Registration  Statement on Form F-1 with respect to
shares of its  Common  Stock on  September  18,  2003.  Due to changes in market
conditions,  it has decided not to proceed  with a blank check  offering at this
time. Accordingly,  no shares of Common Stock have been or will be sold pursuant
to the filed Registration Statement.

     If you have any questions,  please contact Simon Luk of Heller Ehrman White
& McAuliffe at 001-852-2292-2000.

Very truly yours,

Apex Wealth Enterprises Limited

By:  /s/ LI SZE TANG
Name:  Li Sze Tang
Title:  Chief Executive Officer and Chairman of the Board