AMCF [Andatee China Marine Fuel Services] CORRESP: January 21, 2010 VIA EDGAR Mr. H. Roger

[January 21, 2010 VIA EDGAR Mr. H. Roger Schwall Assistant Director Division of Corporation Finance 100 F Street, NE With copies to: Laura Nicholson, Esq. Douglas Brown, Esq. Re: Andatee China Marine Fuel Services Corporation Registration Statement on Form S-1 (File No. 333-161577) Ladies and Gentlemen: Furthermore, please be advised of the following: Any questions should be addressed to Alec]

AMCF [Andatee China Marine Fuel Services] CORRESP: (Original Filing)

[January 21, 2010 Division of Corporate Finance 100 F Street, N.E. Re: Andatee China Marine Fuel Services Corporation Registration Statement on Form S-1 Registration No. 333-161577 (the “Registration Statement”) Dear Ladies and Gentlemen: Sent to Underwriters 1,430 Sent to Dealers 250 Sent to Institutional Investors 140 Sent to Others 850 Total: 2,670 Very truly yours Rodman & Renshaw, LLC Chief]

AMCF [Andatee China Marine Fuel Services] CORRESP: January 21, 2010 Division of Corporate Finance 100

[January 21, 2010 Division of Corporate Finance 100 F Street, N.E. Re: Andatee China Marine Fuel Services Corporation Registration Statement on Form S-1 Registration No. 333-161577 (the “Registration Statement”) Dear Ladies and Gentlemen: Sent to Underwriters 1,430 Sent to Dealers 250 Sent to Institutional Investors 140 Sent to Others 850 Total: 2,670 Very truly yours Rodman & Renshaw, LLC Chief]

AMCF [Andatee China Marine Fuel Services] 8-A12B/A: (Original Filing)

[FORM 8-A/A Amendment No. 1 Amending Form 8-A dated January 20, 2010 FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES Andatee China Marine Fuel Services Corporation Delaware 80-0445030 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) Dalian Ganjingzi District, Dalian Wan Lijiacun Unit C, No. 68 West Binhai Road, Xigang District Dalian People’s Republic of China If this form relates]

AMCF [Andatee China Marine Fuel Services] 8-A12B/A: FORM 8-A/A Amendment No. 1 Amending Form 8-A

[FORM 8-A/A Amendment No. 1 Amending Form 8-A dated January 20, 2010 FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES Andatee China Marine Fuel Services Corporation Delaware 80-0445030 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) Dalian Ganjingzi District, Dalian Wan Lijiacun Unit C, No. 68 West Binhai Road, Xigang District Dalian People’s Republic of China If this form relates]

AMCF [Andatee China Marine Fuel Services] 8-A12B: (Original Filing)

[FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES Andatee China Marine Fuel Services Corporation Delaware 80-0445030 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) Dalian Ganjingzi District, Dalian Wan Lijiacun Unit C, No. 68 West Binhai Road, Xigang District Dalian People’s Republic of China If this form relates to the registration 12(b) of the Exchange Act and is]

AMCF [Andatee China Marine Fuel Services] 8-A12B: FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF

[FORM 8-A FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES Andatee China Marine Fuel Services Corporation Delaware 80-0445030 (State of Incorporation or Organization) (I.R.S. Employer Identification No.) Dalian Ganjingzi District, Dalian Wan Lijiacun Unit C, No. 68 West Binhai Road, Xigang District Dalian People’s Republic of China If this form relates to the registration 12(b) of the Exchange Act and is]

AMCF [Andatee China Marine Fuel Services] S-1/A: (Original Filing)

[PRELIMINARY PROSPECTUS Subject to Completion Dated January 19, 2010 2,500,000 Shares Andatee China Marine Fuel Services Corporation Common Stock This is a firm commitment initial public offering of 2,500,000 shares of our common stock. Prior to this offering, there has been no public market for our common stock. The initial public offering price for the shares of common stock offered] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the use in this Registration Statement on Form S-1 of our reports dated August 24, 2009 (except for the second paragraph of Note1, Note 2(x) and Note 19, as to which the date is November 6, 2009) relating to the combined and consolidated financial statements of Goodwill Rich International] []

AMCF [Andatee China Marine Fuel Services] S-1/A: PRELIMINARY PROSPECTUS Subject to Completion Dated January 19,

[PRELIMINARY PROSPECTUS Subject to Completion Dated January 19, 2010 2,500,000 Shares Andatee China Marine Fuel Services Corporation Common Stock This is a firm commitment initial public offering of 2,500,000 shares of our common stock. Prior to this offering, there has been no public market for our common stock. The initial public offering price for the shares of common stock offered] [CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We hereby consent to the use in this Registration Statement on Form S-1 of our reports dated August 24, 2009 (except for the second paragraph of Note1, Note 2(x) and Note 19, as to which the date is November 6, 2009) relating to the combined and consolidated financial statements of Goodwill Rich International] []

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