ASIA PROPERTIES, INC.
                               114 Magnolia Street
                                  Suite 400-115
                              Bellingham, MA 98225
                                 (360) 992-2841


                                  July 26, 2004

VIA  ELECTRONIC  SUBMISSION

Securities  and  Exchange  Commission
450  Fifth  Street,  N.W.
Judiciary  Plaza
Washington,  D.C.  20549

                  Re:      Asia  Properties,  Inc.  (the  "Company")
                           SEC  File  Number:  333-105921
                           Form  SB-2  Registration  Statement


Ladies  and  Gentlemen:

         We  previously  filed  the  above-referenced  Form  SB-2  registration
statement.  We  hereby  request that such registration statement be withdrawn at
your  earliest convenience.  No securities were offered or sold pursuant to this
registration  statement.  We  request this withdrawal because we have terminated
our  initial  agreement  with  Cornell Capital Partners which formed the primary
securities registered by the SB-2.  We are in the final process of entering into
new  agreements  with  Cornell Capital Partners and will file a new SB-2 at that
time with those documents.  That filing will be accompanied by a response letter
reflecting your comments to the most recent SB-2 filing made by Asia Properties,
Inc.  If  you  have  any  questions  concerning  this matter, please contact the
undersigned or our securities counsel, M. Richard Cutler, Cutler Law Group, 3206
West  Wimbledon  Drive,  Augusta,  GA  30909;  (706)  737-6600.  Please  note
that  all  new  correspondence  should  be  sent  to  Mr.  Cutler.

         Thank  you  for  your  assistance  in  this  matter.


                                            ASIA  PROPERTIES,  INC.


                                            By:  /s/  Daniel  Mckinney
                                                    Daniel  Mckinney
                                                    President