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The following is an excerpt from a SB-2 SEC Filing, filed by AXM PHARMA INC on 6/30/2004.

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PLAN OF DISTRIBUTION

We are registering the shares of common stock on behalf of the selling shareholders. The shares of common stock may be sold in one or more transactions at fixed prices, at prevailing market prices at the time of sale, at prices related to the prevailing market prices, at varying prices determined at the time of sale, or at negotiated prices. These sales may be affected at various times in one or more of the following transactions, or in other kinds of transactions:

o transactions on any national securities exchange or U.S. inter-dealer system of a registered national securities association on which the common stock may be listed or quoted at the time of sale;

o in the over-the-counter market;

o in private transactions and transactions otherwise than on these exchanges or systems or in the over-the-counter market;

o in connection with short sales of the shares;

o by pledge to secure or in payment of debt and other obligations;

o through the writing of options, whether the options are listed on an options exchange or otherwise;

o in connection with the writing of non-traded and exchange-traded call options, in hedge transactions and in settlement of other transactions in standardized or over-the-counter options; or

o through a combination of any of the above transactions.

Each selling shareholder and its successors, including its transferees, pledgees or donees or their successors, may sell the common stock directly to the purchaser or through underwriters, broker-dealers or agents, who may receive compensation in the form of discounts, concessions or commissions from the selling stockholder or the purchaser. These discounts, concessions or commissions as to any particular underwriter, broker-dealer or agent may be in excess of those customary in the types of transactions involved.

The selling security holders and any broker-dealers or agents that are involved in selling the shares may be deemed to be "underwriters" within the meaning of the Securities Act in connection with these sales. In that event, any commissions received by these broker-dealers or agents and any profit on the resale of the shares purchased by them may be deemed to be underwriting commissions or discounts under the Securities Act.

In addition, any securities covered by this prospectus which qualify for sale pursuant to Rule 144 of the Securities Act may be sold under Rule 144 rather than pursuant to this prospectus.

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We have entered into registration rights agreements for the benefit of the selling shareholders to register the common stock under applicable federal and state securities laws. The registration rights agreements provide for cross-indemnification of the selling shareholders and us and our respective directors, officers and controlling persons against specific liabilities in connection with the offer and sale of the common stock, including liabilities under the Securities Act. We will pay substantially all of the expenses incurred by the selling shareholders incident to the registration of the offering and sale of the common stock.

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THE PHARMACEUTICAL MARKET
IN THE PEOPLE'S REPUBLIC OF CHINA

The Peoples Republic of China is one of the world's major producers of pharmaceuticals. According to IMS Market Research Consulting (Shanghai) currently there are approximately 6,000 pharmaceutical manufacturers operating in The Peoples Republic of China, with the capacity to produce 1,350 ethical drugs and more than 8,000 traditional Chinese medicines. In 2000, the The Peoples Republic of China's pharmaceutical industry had aggregate sales of US$28.2 billion, which represented a 22% increase over aggregate sales in 1999.(1)

Impact of Accession to World Trade Organization. Due in part to the relaxation of trade barriers following The Peoples Republic of China's accession to the World Trade Organization in January 2002, we believe The Peoples Republic of China will become one of the world's largest pharmaceutical markets by the middle of the twenty-first century. As a result, we believe the Chinese market presents a significant opportunity for both domestic and foreign drug manufacturers. With the Chinese accession to the World Trade Organization, the Chinese pharmaceutical industry is gearing up to face the new patent regime that is required by World Trade Organization regulation, and the Chinese government has begun to reduce its average tariff on pharmaceuticals. The Peoples Republic of China has also agreed that foreign companies will be allowed to import most products, including pharmaceuticals, into any part of The Peoples Republic of China. Current trading rights and distribution restrictions are to be phased out over a three-year period. In the sensitive area of intellectual property rights, The Peoples Republic of China has agreed to implement the trade-related intellectual property agreement of the Uruguay Round. There can be no assurances that The Peoples Republic of China will implement any or all of the requirements of its membership in the World Trade Organization in a timely manner, if at all.

The Peoples Republic of China's pharmaceutical industry was opened to outside markets earlier than other industrial sectors. With the reduction of tariffs, The Peoples Republic of China will not only be able to import advanced drugs, but many small and medium-sized foreign companies with independent patents will also be able to enter the market. Since The Peoples Republic of China's entry into the World Trade Organization, international pharmaceutical companies are now able to acquire a large share of the Chinese pharmaceutical market. These companies may be able to gain total control over their distribution networks and not have to rely on the complex and costly Chinese supply network. An open market will give international companies a better opportunity of having their products included on The Peoples Republic of China's provincial and municipal lists of drugs that are subject to state reimbursement. In addition, the intellectual property rights of foreign manufacturers may be better protected.

Traditional Chinese medicines are likely to be less affected by The Peoples Republic of China's World Trade Organization accession. However, it is expected that The Peoples Republic of China will have to develop and utilize modern laboratory methods to demonstrate the efficacy of Traditional Chinese medicines. In addition, The Peoples Republic of China is requiring manufacturers of Western prescription and over-the-counter medicines that conform to new international standards of quality and efficacy. The Chinese government is determined to nurture its own large pharmaceutical companies, while reducing the number of small companies. It is anticipated that this government determination will boost the quality of Chinese medicine and enhance The Peoples Republic of China's ability to compete in world markets.

Foreign drug companies are expected to benefit from The Peoples Republic of China's World Trade Organization accession in three significant areas: First, they will be able to acquire a larger share of the Chinese market; open competition will give foreign drug companies a better chance of having their products included on The Peoples Republic of China's provincial and municipal lists of drugs that are subject to state reimbursement. Second, they may be able to gain increased control over their distribution networks and may not have to rely on the complex and costly Chinese supply network. Finally, the intellectual property rights of foreign drug companies will be accorded enhanced protection. However, given The Peoples Republic of China's past performance in adhering to international agreements, there can be no assurance that any or all of these benefits will be achieved.

Regional Industry Development. The eastern coastal areas of The Peoples Republic of China are still the source of the greatest sales growth of The Peoples Republic of China's pharmaceutical industry. The value added of



(1) The statistics and market data regarding the Pharmaceutical Market in the Peoples Republic of China was based upon the report titled "IMS Market Research Consulting (Shanghai), Market Prognosis Asia, 2003-2007, China Report," prepared by IMS Market Research Consulting (Shanghai) is a subsidiary IMS Health (NYSE:
RX) ("IMS"), a global pharmaceutical market research company, operating in China.

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the 12 coastal economically-developed provinces and municipalities, including Jiangsu, Zhejiang, Shandong, Guangdong, Liaoning, Shanghai and Beijing, comprised approximately 64% of the total sales growth over the period from 2000 to 2002. Seven of the 16 Chinese provinces, municipalities and autonomous regions reported a 20% or more growth rate from 2000 to 2002.

THE PEOPLES REPUBLIC OF CHINA'S OVER-THE-COUNTER MARKET DRIVERS

We believe the following factors are the key market-driving forces in the projected growth of The Peoples Republic of China's over-the-counter pharmaceutical industry:

Government Policy. The State Food and Drug Administration of The Peoples Republic of China set up an administrative system in 1999 for the classification of pharmaceutical products into the categories of prescription and over-the-counter drugs. Since then, the State Food and Drug Administration has issued a series of guidelines on the interpretation of the new classification system on labeling, usage instructions and packaging of over-the-counter products. . At present, there are approximately 700 over-the-counter drugs classified by the State Food and Drug Administration. A second group of over-the-counter drugs is under consideration by the State Food and Drug Administration in consultation with the Chinese pharmaceutical industry. According to the State Food and Drug Administration's plan, it is estimated that approximately 70% of registered drugs will be classified as over-the-counter.

Economic and Social Development. In The Peoples Republic of China, awareness is increasing about health care and the importance of self-medication. The rapid rise in living standards and disposable income has made possible self-medication on a continued basis for a large number of people. We believe achievement of satisfactory results through such easy self-health management is winning over an increasingly large number of people across age groups. The domestic over-the-counter market is also expanding as a result of rapid growth in target urban consumer populations. Currently, the total number of non-state-owned-enterprise workers (workers who are not covered by state health insurance) has overtaken that of state-owned-enterprise employees. Increased levels of international exchange and commercial activity have greatly added to the number of tourists and mobile populations, which, compared with other populations, tend to have higher incomes. The ongoing and proposed future reforms to the healthcare insurance system should divert more of the population to self-medication and over-the-counter consumption. Rural areas likely will become large potential markets for over-the-counter drugs. We believe the relative safety, low toxicity, efficacy, ease of use, and reasonable pricing of most over-the-counter drugs will make many over-the-counter drugs a preferred choice for the rural healthcare market in which medical services are scarce and virtually non-existent in remote locations.

Technical Development. Adjustment in drug usage patterns should also push the over-the-counter market forward. In recent years, the conversion from prescription to over-the-counter drugs has become more frequent, which has resulted in a widening range of diseases and symptoms for which over-the-counter drugs are available. Consumption of nutritional supplements and medicated cosmetics in the over-the-counter sector is increasing, which should further enlarge the scope of over-the-counter application.

The Peoples Republic of China's Drugstore Development. The development of the retail drugstore sector in The Peoples Republic of China since the most recent round of healthcare reforms began in 1998 has been rapid. Chain drugstores soon followed; since the promulgation of Chain Drugstores Regulations in 1998, more than 260 companies have been approved by the State Food and Drug Administration as chain drugstores. Of the roughly 120,000 Chinese retail pharmacies as of December 2002, 260 were chain drugstore enterprises that managed in the aggregate 5,096 retail outlets. According to recent industry figures, there are an average of 26 retail drugstores for each chain; and the largest chain had a total of 231 interregional retail outlets. As of December 2002, the largest retail sales of a chain drugstore in The Peoples Republic of China amounted to RMB300.0 million, or US$36.59 million.

Chinese Consumers Trends. Recent consumer studies indicate that 86% of drug stores in Beijing carry promotional advertising inside the retail outlet, while another 59% use advertisements for external window displays. Seventy-one of the 100 drug stores surveyed also hosted on-site promotional events conducted by drug manufacturers. Television and radio commercials, pamphlets, journal and newsletter advertising, billboards and medical information hotlines are also used by manufacturers to promote their drug products to the public. Although more than half of the average urban consumers in The Peoples Republic of China know the brand names of commonly advertised over-the-counter products, only 16% are influenced by advertising to buy these products. The caution of Chinese

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consumers may stem from years of exposure to aggressive but medically unsubstantiated claims of efficacy advertised by some Chinese manufacturers, especially those dealing with herbal medicines. Although the State Food and Drug Administration's "truth in advertising" regulations have sought to curtail the advertising of cure-all products, the tendency of medically unsubstantiated claims persists among some Chinese manufacturers and the State Food and Drug Administration is unable to police all violations. In addition, recent studies show that the drug store sales clerks play a major role in influencing the consumer in his or her drug purchases. Sales clerk input and on-site educational promotion of products accounted for 58% of consumer selection, while counter displays attracted another 25.8%. We believe retail drug store outlets should play a powerful role in the development of The Peoples Republic of China's pharmaceutical market for prescription and non-prescription pharmaceutical products. Barring radical changes in The Peoples Republic of China's medical reform policies, the average consumer will increasingly be buying medication at retail drug stores.

THE PEOPLES REPUBLIC OF CHINA'S OVER-THE-COUNTER MARKET CHARACTERISTICS

The following are the three key market characteristics of the Chinese over-the-counter pharmaceutical marketplace.

Production and Price. Relatively simple off-patent technology makes entry barriers low. Brand sensitivity is much stronger than price sensitivity due to low price elasticity. It is very important to build branding and consumer awareness because of the fragmentation of production and low price elasticity.

Promotion and Advertising. Typically, promotion and advertising expenditure account for approximately 20-25% of the total sales turnover of over-the-counter drugs. Advertising expenditure on television dominates. Other promotional tools include point-of-purchase displays and medical magazines.

Distribution Channels. Distribution channels for over-the-counter drugs include chain pharmacies, hospitals, direct sales, department stores and supermarkets. For decades, the government has controlled The Peoples Republic of China's drug distribution industry, and chain pharmacies have appeared only in the past five years. The increase in over-the-counter sales has led to the rapid development of chain pharmacies in Chinese cities. In 2000, there were over 200 intra-province chain pharmacies, with approximately 5,000 stores nation-wide.

GENERAL CHINESE MARKET STATISTICS

The Peoples Republic of China is one of the largest markets in the world and we believe the growth potential is significant. The country has a massive population of approximately 1.4 billion people. According to the Chinese Statistics Bureau, at December 31, 2000, the Chinese market had the following growth factors:

a. Gross Domestic Product ("GDP") growth rate: 9.6%;
b. Urban growth rate: 10% - 30%;
c. Urban per capital income: RMB 8,596 (US$1,036);
d. Retail sales: RMB 2,098 billion (US$253 billion);
e. Population: 1.4 billion;
f. Area: 9.6 million square km;
g. Key cities: 1,000; and
h. Urban dwellers: 27% (329 million).

FOREIGN INVESTMENT IN THE PEOPLES REPUBLIC OF CHINA'S PHARMACEUTICAL INDUSTRY

Pharmaceuticals produced by Sino-foreign joint ventures in The Peoples Republic of China and imported drugs account for one third of the Chinese market. As of December 2000, approximately 1,700 pharmaceutical joint ventures had been established in The Peoples Republic of China, with investment totaling approximately US$2 billion and 40% of all Chinese pharmaceutical enterprises having utilized overseas capital. Of the 25 largest multinational pharmaceutical companies, 20 had established a presence in The Peoples Republic of China, with 40 of the 50 most popular branded drugs in The Peoples Republic of China produced by Sino-foreign joint ventures. In terms of sales volume, the leading joint venture is Xi'an-Janssen Pharmaceutical, a collaboration between Johnson & Johnson and the Shanxi Provincial Corporation of Pharmaceutical Industries. Tanjin Smith Kline & French Laboratories, which is owned 55% by SmithKline Beecham, leads the over-the-counter market, and Shanghai Squibb Pharmaceuticals Products, which is partly owned by Bristol-Myers Squibb, has been successful in

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both urban hospitals and the over-the-counter market. A recent joint venture includes Shanghai Sankyo Pharmaceutical, a joint venture between Sankyo Seiyaku, a Japanese company that is the 95% owner, and Shanghai Zhangjiang Science and Technology Park Development, which markets six of Sankyo's products.

The rate at which foreign companies are establishing joint ventures with Chinese enterprises and increasing their financial investment has significantly increased in the last two years. In 2000, Celera Genomics, a U.S. company, acquired a 47.5% stake in Shanghai GeneCore BioTechnologies, with a view to expanding globally and gaining access to new sources of genetic information. Nutricia, a Dutch company, has invested US$20 million to form a wholly-owned subsidiary, Nutricia Pharmaceutical (Wuxi), to produce proprietary nutritional products.

The Chinese market is highly fragmented with a large number of manufacturers and distributors. There are over 6,000 pharmaceutical firms in The Peoples Republic of China, many of which are small local enterprises. In a move to improve the competitive edge of The Peoples Republic of China's pharmaceutical industry in the international market, in 2000, the Ministry of Commerce announced plans to consolidate nearly 5,000 state owned firms into 12 large pharmaceutical firms to compete with the world's leading drug producers. During the next five years, the Ministry of Commerce expects these 12 large pharmaceutical firms to play a significant role in the domestic and international arena, and they will be granted priority for technical renovation and research and development. The Peoples Republic of China has set up over 200 research institutes for biotechnology and more than 140 enterprises are engaged in related development and production. The Ministry of Commerce also supports foreign pharmaceutical companies in expanding their businesses and in setting up research centers to develop new products. Foreign-funded research centers would be exempt from import tariff and custom taxes; business taxes would also be exempt if foreign companies transfer technology to Chinese-based entities.

Difficulties faced by foreign firms entering the Chinese market include the lack of protection of intellectual property rights, drug counterfeiting, price controls, limited social security, medical insurance and prescription coverage. See "Risk Factors - Risks Relating to the Pharmaceutical Industry in The People's Republic of China."

BUSINESS

OVERVIEW

We are a China-based pharmaceutical company that, through our wholly-owned subsidiary, Werke Pharmaceuticals, Inc. owns 100% of AXM Shenyang, a Wholly Foreign Owned Enterprise organized under the laws of The Peoples Republic of China.

Werke Pharmaceuticals was organized on November 29, 2000, in order to enter the Chinese Pharmaeutical Industry. Werke had the capability to organize and expand an existing China-based Pharmaceutical company, as the Chinese industry accelerated the process of privatization of State Owned Pharmaceutical Companies. Toward that end, on January 26, 2001, Werke Pharmaceuticals entered into an equity joint venture with Shenyang Tianwei Pharmaceutical Factory, Ltd., a Chinese company that manufactured and marketed pharmaceuticals in The Peoples Republic of China, which contributed its assets and operations to the joint venture. The equity joint venture was organized under the name Shenyang Tianwei Werke Pharmaceuticals Co., Ltd., which was changed to AXM Pharma Shenyang, Inc. in April 2004. The shareholders of Shenyang Tianwei Pharmaceutical Factory later converted their interest in the equity joint venture into shares of Werke Pharmaceuticals in anticipation of Werke Pharmaceuticals' reverse acquisition of Wickliffe International Corporation. Upon the conversion of the interest of the shareholders of Shenyang Tianwei Pharmaceutical Factory into shares of Werke Pharmaceuticals, the joint venture was granted permission and rights to become a Wholly Foreign Owned Enterprise. As a result of the change of status of Shenyang Tiawei Werke Pharmaceutical Factory from an equity joint venture to a Wholly Foreign Owned Enterprise, AXM Shenyang became the wholly owned operating subsidiary of Werke. Immediately prior to its reverse acquisition of Wickliffe International, Werke's sole business was conducted through its wholly owned subsidiary Shenyang Tianwei Werke Pharmaceuticals. Wickliffe International had no operations immediately prior to its business combination with Werke. Following the reverse acquisition of Wickliffe International, Wickliffe International became the parent of Werke Pharmaceuticals and AXM Shenyang. Also following the reverse acquisition Wickliffe International Corporation changed its name to Axiom Pharmaceuticals, Inc., and subsequently to AXM Pharma, Inc.

Our subsidiary, AXM Shenyang, is classified under Chinese Company Law as a

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Wholly Foreign Owned Enterprise. Wholly Foreign Owned Enterprises have recently become the investment vehicle of choice for foreign investors who wish to manufacture, process, or assemble products in China. Wholly Foreign Owned Enterprises are limited liability companies established under Chinese Company Law, which are owned exclusively by one or more foreign investors and thus offer controls over the company's management, technology, and finances that the typical foreign investor requires. From a foreign investors' point of view, the advantages of establishing a Wholly Foreign Owned Enterprise include:

o Independence and freedom to implement the worldwide strategies of its parent company without having to consider the involvement of a Chinese partner;

o Ability to carry on business rather than just a representative office function;

o Ability to issue invoices to their customers in Renminbi (Chinese Currency) and receive Renminbi revenues;

o Ability to convert Renminbi profits to US dollars for remittance to their parent company outside China;

o Ability to employ staff directly within China;

o Protection of intellectual know-how technology;

o Greater efficiency in its operations, management and future development; and

o No requirement to share profits with another party.

In summary, the key differences between a Wholly Foreign Owned Enterprise and an equity or cooperative joint venture are that the joint venture business structure requires profit sharing between the stake holders, significant involvement in operational and business matters by the Chinese stake holders, indirect representation in business matters and much less effective and efficient cooperation between the stake holders. Typically, the foreign party to a Chinese joint venture experiences significantly less control over the business structure than if the foreign party forms a Wholly Foreign Owned Enterprise or converts an existing joint venture into a Wholly Foreign Owned Enterprise.

There may of course be disadvantages to operating as a Wholly Foreign Owned Enterprise. For example, should we become subject to liabilities that arise from our operations in The Peoples Republic of China, we would be wholly responsible for such liabilities. In a joint venture, the foreign investor would only be liable for that portion of the liability, which corresponds to its ownership in the joint venture. Also, as a result of our wholly foreign ownership, we may receive less favorable treatment from governmental agencies in The Peoples Republic of China and other Chinese companies than we would receive if we had a Chinese Partner. To date we have not experienced any such disadvantages in operating our business as a Wholly Foreign Owned Enterprise.

Despite the possible disadvantages to operating as a Wholly Foreign Owned Enterprise, we feel that the advantages outweigh the disadvantages. With regard to AXM Pharma, the advantage of being able to own 100% of our Chinese operating subsidiary is particularly important because of our status as a U.S. public company. We believe that newly formed businesses will also see the advantages to operating as a Wholly Foreign Owned Enterprise and that most such businesses will, if permitted by the Chinese government, choose the use of the Wholly Foreign Owned Enterprise structure over the joint venture structure. It is also anticipated that many existing joint ventures are likely to migrate their corporate structures to Wholly Foreign Owned Enterprises over the next five years.

AXM Shenyang is located in the City of Shenyang, which is in the Province of Liaoning in the Northeastern section of The Peoples Republic of China. AXM Shenyang and its predecessor company, Shenyang Tianwei Pharmaceutical Factory, Ltd. have an operating history of approximately 10 years. AXM Shenyang historically has been a manufacturer and distributor of proprietary and generic pharmaceutical products, which include injectables, capsules, tablets, liquids and medicated skin products for export and domestic Chinese sales. The products produced by AXM Shenyang in the past three years have focused on relief of selective symptoms of upper respiratory infection, skin irritation and rash, infectious disease. We currently own 43 product permits, of which only four permits are currently commercialized. AXM Shenyang's Shenyang plant was decommissioned in 2002 due to the significant growth of the population of Shenyang that caused the surrounding area to change from a city-edge industrial

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area to a city-center, non-industrial urban residential neighborhood. As part of a broad-based corporate development strategy, the Shenyang plant is anticipated to be contributed to a city sponsored commercial/residential real estate development. However, since we did not own the land upon which the old factory was located, we do not anticipate receiving any material reimbursement for our contribution of the plant. Furthermore, the compensation we may receive, if any, is not expected to have a material affect on our results of operations or financial condition. AXM Shenyang currently utilizes a third-party original equipment manufacturing pharmaceutical plant to produce all of its products and distributes its products only through third-party distributors. AXM Pharma has a marketing field force of 22 persons.

We are utilizing a portion of the net proceeds from our sale of the Preferred Stock to build a modern production and distribution facility, which we plan to qualify under United States Good Manufacturing Practice regulations. The site of our new plant is located in a special economic zone located several kilometers from the old plant. We have engaged Liaoning Pharmaceutical Design & Engineering Company as our design company. Liaoning Pharmaceutical Design & Engineering Company has provided us with the following estimates in its report to us titled the " Basis for Design":

o Construction and installation of equipment: December 2003-July 2004
o Trial batch production: August 2004-September 2004
o Chinese Good Manufacturing Practices licensing: October 2004-November 2004
o US Food and Drug and Administration inspection and certification: to be scheduled

Prior to closing the old plant, we had approximately 320 employees. By utilizing third-party original equipment manufacturing manufacturing relationships, our head count has dropped to approximately 35 employees. We anticipate that when the new facility is certified and becomes operational our total headcount will likely approach the former number of employees and selected third-party original equipment manufacturing production will be discontinued.

AXM Shenyang has chosen to locate its new production facility in the Shenyang Hunnan National New & High-Tech Industrial Development District. This special economic district is located at the southern part of the city of Shenyang with a total area of approximately 120 square kilometers. The development and construction of the High-Tech Industrial Development District is a major step for Shenyang's economic and social development. We expect to complete the construction and governmental approval process for the new facility by the fourth quarter of fiscal 2004. We believe construction of the new facility will provide us with the ability to meet current demand within The Peoples Republic of China and with the flexibility to add production capacity to meet future product requirements both within The Peoples Republic of China and for potential export markets. We believe construction of the new facility will provide significant operational and financial benefits as a result of our ability to implement operational effectiveness as well as offer greater control over quality assurance and production scheduling and capacity.

The new Shenyang facility is designed to meet stringent U.S. Good Manufacturing Practice protocols. By meeting such protocols, we believe we will be in a position to expand our marketing and sales activities to include exports to neighboring Asia-Pacific countries, as well as North America, Europe and Africa. In addition, we believe we will be better positioned to actively seek and engage foreign ethical and over-the-counter drug manufacturers that are searching for high-quality, low-cost manufacturing capabilities for their high demand medications.

The High-Tech Industrial Development District was established in May of 1988 order to accelerate the development and industrialization of high-tech industries in the North-Eastern portion of the Peoples Republic of China. After thirteen years of development, it has successfully attracted various high-tech industries, including: biotechnology, pharmaceuticals, software, digital technology, robots, nano-materials and a distribution center for IT products. Currently, over 480 foreign enterprises including General Motors, Toshiba and LG that have set up offices or manufacturing facilities in the High-Tech Industrial Development District.

In order to create unique incentives for companies to locate in the High-Tech Industrial Development District, favorable corporate income rates have been established. The income tax rate for those companies that have chosen to locate in the High-Tech Industrial Development District will be levied at 15 percent annually. Newly founded high-tech enterprises, including AXM Shenyang, will enjoy exemption from income tax for 2 years from the first year of operation.

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GROWTH STRATEGY

We believe we have a low risk corporate development strategy in that we intend to organically grow our operational revenue using currently profitable products commercializing products for which permits are issued. Our strategy includes a focus on branding and marketing. We plan to attract unique molecules from large pharmaceutical and drug discovery companies through license agreements. We will continue to sell in the Peoples Republic of China. The addition of revenues through international sales of our products and/or acquisitions will only be considered if they are deemed to enhance our revenue and profitability. Utilizing our low risk growth strategy, however, we believe that we can become a leading China-based, current Good Manufacturing Practice-qualified pharmaceutical manufacturer and distributor, with certification from the U.S. Food and Drug Administration and the Chinese State Food and Drug Administration. To reach our goals, we intend to implement the following strategy:

Construction of US Good Manufacturing Practice-qualified Manufacturing Facility. We began construction in January 2004 of a new U.S. Good Manufacturing Practice-qualified pharmaceutical manufacturing facility in the special economic zone in Shenyang. The Good Manufacturing Practice Regulations are promulgated by the United States Food and Drug Administration under the authority of the Federal Food, Drug and Cosmetic Act. These regulations, which have the force of law, require that manufacturers, processors and packagers of drugs, medical devices, some foods, and blood take proactive steps to ensure their products are safe, pure and effective. Good Manufacturing Practices regulations require a quality approach to manufacturing, enabling companies to minimize or eliminate instances of contamination, mix-ups and errors. Failure of firms to comply with Good Manufacturing Practices regulations can result in serious penalties, including recall, seizure, fine and imprisonment. We expect to complete the construction and governmental approval process by the fourth quarter of fiscal 2004. We believe construction of the new plant will provide us with the ability to meet current demand within The Peoples Republic of China and with the flexibility to add production capacity to meet future product requirements both within The Peoples Republic of China and for potential export markets. We believe construction of the new plant will provide significant operational and financial benefits as a result of our ability to implement operational effectiveness as well as offer greater control over quality assurance and production scheduling and capacity.

The new Shenyang facility has been designed to meet stringent U.S. Good Manufacturing Practice protocols. By meeting such protocols, we believe we will be in a position to expand our marketing and sales activities to include exports to neighboring Asia-Pacific countries, as well as North America, Europe and Africa. In addition, we believe we will be better positioned to actively seek and engage foreign ethical and over-the-counter drug manufacturers that are searching for high-quality, low-cost manufacturing capabilities for their high demand medications.

Product Range Expansion. Anticipating completion of our new manufacturing facility, we are undertaking to expand our existing product line by exploiting our existing base of licensed products, internal research and development of new formulas, as well as acquiring new ethical and over-the-counter pharmaceutical products licensed from drug manufacturers based in North America, Europe and Japan. Initially, selection of new products will be determined by criteria such as: (a) molecules that can achieve a unique or competitive positioning in the market relative to the competition in selected therapeutic categories, (b) the size of the market, (c) the price premium available based on the government's pricing mechanism in force at the time and the projected profit margins, and (d) The opportunity available at the time to market the products and have the product purchased through channels other than government hospital tender purchasing. Our objective will be to maximize return on investment and still benefit from proposed collaborative partners. We believe cancer, respiratory disease, diabetes, cardiovascular and infectious diseases represent significant therapeutic opportunities. In addition, we intend to focus on products developed from original molecules that work in unique ways compared to the competition, that have large potential markets and can be further differentiated through effective branding strategies. This strategy should greatly limit the number of potential competitors and help us maintain higher profit margins. We anticipate attempting to develop a portfolio of molecules and brands in selected therapeutic categories and introduce new products each year, that have significant intellectual property protection. Toward this end, in January 2004, we entered into a licensing agreement to manufacture, market and sell certain vitamin and vitamin supplements in The Peoples Republic of China under the Sunkist brand name and trademark. The agreement grants AXM Pharma exclusive rights in The Peoples Republic of China, excluding Macao and Hong Kong, for use of the Sunkist brand name for AXM Pharma's range of vitamin and vitamin supplements (excluding vitamin-fortified confections). The agreement also grants AXM Pharma a right of first refusal for any territory in the rest of Asia where Sunkist does not currently license the product categories covered by their agreement with AXM Pharma. Under the terms of the agreement, we are required to achieve certain sales targets each year, for each category of product licensed under the agreement. If we fail to achieve the agreed upon

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sales targets for any two consecutive years, the agreement may be terminated with regard to such product category by Sunkist in its discretion. Supporting the license, we are entering into agreements to secure the transfer of new manufacturing methods for traditional product forms and for product forms that will be new in China. Additionally, advances in manufacturing methods will be deployed in the manufacture of the product Qiyao, an adjunctive therapy for the treatment of type II diabetes, the rights to which we recently acquired.

Expand Marketing and Sales. As we build and commission a factory achieving current Good Manufacturing Practice standards, we intend to expand our marketing and sales capabilities, first in The Peoples Republic of China, then internationally. We anticipate that initially we will seek to expand our current domestic distribution capabilities beyond the regions in which we currently sell. To achieve this goal, we expect to expand the current successful in-house marketing and sales capacity, as well as to engage additional domestic third-party distributors to penetrate new markets. We are also developing more extensive educational programs for hospitals, doctors, clinics and distributors with respect to our product lines. We expect these educational programs to significantly improve the sell through and promotion of our products.

PRODUCTS

Licensing and Intellectual Property

The State Food and Drug Administration of the Government of The Peoples Republic of China issues the licenses and permits for permission to market and manufacture pharmaceutical products in The Peoples Republic of China. Generally, licenses and permits issued by the State Food and Drug Administration are revocable by the State Food and Drug Administration at any time, with or without cause. AXM Shenyang has been granted 43 product licenses and permits, of which only four licenses currently are commercialized. AXM Shenyang will likely undertake a selection process to decide which of its remaining licenses, if any, will be commercialized, and to determine the timeframe for such commercialization over the next 10 years. AXM Shenyang operates in both the over-the-counter and the prescription pharmaceutical product market segments. None of our registered products are currently patented nor do we have any patents pending before the government of The Peoples Republic of China or any other government.

Current Product Line

The five compounds we currently manufacture are listed below. Note of the five compounds listed, four are commercialized, Lifupeng is available upon request from government hospitals only, as a service item.

Asarone, which is manufactured in tablet form, is indicated for bronchial infection and bronchial constriction (symptoms of upper respiratory infection).

Weifukang is an antiseptic cream for cleansing acne and for relieving the symptoms of eczema, psoriasis and other skin irritations, such as contact dermatitis.

Cefalexine, Cefalexine is a broad-spectrum antibiotic. It has high sensitivity to staphylococcus, streptococcus, pneumococcus, gonococcus, diplococcus meningitis and others. Cephalexine is approved for and registered for the treatment of respiratory infections; genitourinary tract infections; skin and soft tissue infections; abdominal (gastric) infections; and oral infections.

Norfloxacin is a medium spectrum antibiotic that is primarily positioned for gastric and urinary infection.

Lifupeng, Rifampicin is used for treatment of tuberculosis.

We currently manufacture five products, which include:

REGISTRATION STATUS DISTRIBUTION CHANNEL SALES (%RX, PRODUCT (RX OR OTC) % OTC) ------- ------------------- --------------------------------

Cafalexine, an antibiotic Rx 100%Rx

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Weifukang skin cream OTC 100% OTC

Norfloxacin, an antibiotic Rx 100% Rx

Lifupeng (Rifampacin) for Rx 100% Rx Tuberculosis

Asarone alpha (tablets) OTC/Rx 33% OTC/67%Rx

We recently made a strategic decision to cease sales of our Cefalexin and Norflexin antibiotic products due to their significantly decreasing gross profit margins. Antibiotic pricing is under significant pressure from government hospital purchasers who are reducing the price they are willing to pay for antibiotics by up to 20% per year.

Total Permitted and Licensed Products

The following table lists all of the compounds for which AXM Shenyang has permits to manufacture and market. We currently only produce and market the five products listed above. To date we have not commercialized any of the other compounds listed below because our strategy is to focus on branding and brand development prior to introducing new product lines. At present our focus is on establishing and expanding sales of the brands which we have already launched. However, we plan to introduce two new products in 2004 and two additional products in each subsequent year. We have not yet determined which products we will introduce in 2004. The State Food and Drug Administration has recently ordered pharmaceutical companies in The Peoples Republic of China to stop producing two of the 43 products listed below, Meleumcyin Tablets and Arsoer Tabellae for Common Cold. As a result, the State Food and Drug Administration will not renew these licenses in the future. However, we do not feel that this will have an adverse effect on our business since we are not currently commercializing these two products.


NAME


Tabellae Asarone

Compoint Sulfamethoxazole

Tabellae Amidopyririni Et Caffeini

Pharacetamol

Amidopyrini Et Paracetamoli Compositae

Metamizole Sodium

Tabellae Acidi Acetysalicylici Compositae

Erythromycin

Erthromycin Ethylsuccinate

Acetylspiramycini

Inosini

Chloramphenicol

Berberine Hydrochloride

Fenofibrate

Meleumycin

Tabellae Natril Bicarbonatis Cum Rheo Et Gentiana

Tabellae Acetamidopyrrolidoni

Vitamin C

Cyproheptadine Hydrochloride

Arsoer Tabellae for Common Cold

Atenolol

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NAME


Lid Tabellae for Stomach-Regulating

Glucosum Pro Orale

Norfloxacin

Norflaxacin

Ke Kuai Hao for treating Cough

Fu Pai Shuan

Nifedipine

Tolperisoni Hydrochloridi

Cefalexini Compositum

Rifampicin

Indometacin

Acetamidopyrrolidoni

Pipemidic Acid

Paracetamoli Compositae

Capsules for Removing Erethism

Albendazol

Xiaoling for Common Cold

Weifukang Cream

Weifukang Cream

Anti-Chap Skin Cream

Unguentum Griseofulrini Compositum

Unguentum Methylis Salicylatis Compositum

Compound Zinc Undecylenate, Ointment

Cremor Crotamitoni

Clycerol

In addition to the licenses for the products listed above, we acquired the rights to Qiyao, an adjunctive therapy for Type II diabetes, Sunkist Vitamin Range and Whisper Feminine Hygiene Wash. We intend to manufacture, market and sell these products.

CURRENT THIRD PARTY ORIGINAL EQUIPMENT MANUFACTURING

Qiqihaer Pharmaceutical Factory 2 of Heilong Group, which is located in the City of Qiqihaer, Heilonjiang Province, manufactures the following products pursuant to an original equipment manufacturing agreement. These products constitute all of the products sold by AXM Pharma at this time.

o Asarone Tablets
o Cefalexine Capsules
o Norfloxacin Capsules
o Weifukang Antiseptic Cream
o Lifupeng Granules.

Our agreement with Qiqihaer Pharmaceutical Factory 2, which we entered into in September 2002, requires Qiqihaer Pharmaceutical Factory 2 to manufacture those products that we designate. Under the agreement, Qiqihaer Pharmaceutical Factory 2 must manufacture our products based on quality control variables and timetables supplied by us. We are obligated to pay Qiqihaer Pharmaceutical Factory 2 for product at the time of the completion of the manufacturing process. Qiqihaer Pharmaceutical Factory 2 is prohibited from selling any of our products. Qiqihaer Pharmaceutical Factory 2 is a medium-sized pharmaceutical factory with approximately 600 employees and over 34 years of operating history. It manufactures injectables, tablets, capsules and other pharmaceutical products for itself and unaffiliated third parties. In 2000 Qiqihaer Pharmaceutical Factory 2 received a Certificate of Good Manufacturing Practices for Human Drugs from the State Food and Drug Administration. The certification remains valid until 2008. Our agreement with Qiqihaer Pharmaceutical Factory 2 expires in September 2004. We anticipate that most of

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the products that are currently manufactured for us by Qiqihaer Pharmaceutical Factory 2 will be manufactured in our new factory in Shenyang, which is currently under construction. We have, however, begun discussions with other third-party manufacturers whom we may employ if our new facility is not complete prior to the expiration of our agreement with Qiqihaer Pharmaceutical Factory 2 or in the event that it is more cost-effective to continue third-party production of certain products. Until the opening of our new manufacturing facility, we willsupport the launch of the new product ranges by entering into a repackaging agreement to increase manufacturing capacity.

CURRENT SALES AND MARKETING

Our products are currently sold and distributed through only one third-party pharmaceutical distributor, Liaoning Weikang Medicine Co. Pursuant to an agreement between our predecessor company, Shenyang Tianwei Pharmaceutical Factory and Liaoning Weikang Medicine Co., we have granted Liaoning Weikang Medicine Co. exclusive rights to distribute our products in Shenyang. Under terms of our agreement with Liaoning Weikang Medicine Co., our prices must be competitive with other suppliers. Due to the exclusive nature of our agreement with Liaoning Weikang Medicine Co., we are not permitted to sell our products to other customers in Shenyang. Liaoning Weikang Medicine Co. is required to pay for our products in cash at the time of sale. Also, pursuant to an oral agreement, we permit Liaoning Weikang Medicine. Co. to sell our products through sub-distributors in seven territories, including Guangdong, Heilongjiang, Jilin, Fujian, Liaoning and Inner Mongolia and the city of Shanghai. Its sub-distributors include Shanghai Shenwei Drug Co., Guangzhou Kangning Drug Co., and Guangzhou Mingsheng Drug Co. We believe other distributor relationships will be available on comparable terms should any of our existing sales and marketing relationships be terminated. Our agreement with Liaoning Weikang Medicine. Co. expires in March 2004. Liaoning Weikang Medicine. Co. has verbally agreed to continue its distribution relationship with us and we anticipate renewing our relationship with Liaoning Weikang Medicine. Co. for distribution in Liaoning Province. Additionally, we are currently negotiating with several other distributors for distribution of our products in additional provinces in the Peoples Republic of China.

COMPETITION

At present, we do not have a single main competitor. Rather, we compete with different companies in different therapeutic categories. For example, with regard to Asarone Tablets, the product from which we derive the most revenue, we compete with Liuzhou Pharmaceutical Factory, located in Liuzhou City, Guang Xi Autonomous Region. AXM and Liuzhou are the only two companies approved by the State Food and Drug Administration to manufacture Asarone Tablets. However because Liuzhou distributes its Asarone tablets mainly in Southern China and AXM distributes its products mainly in Northern China, the two companies do not really compete head to head in their respective markets. We compete with two companies for distribution of our product Weifukang herbal antiseptic skin cream, Zhejiang Wenzhou Pharmaceutical Factory and Ying Kou Biochemical Pharmaceutical Factory. However, one of these competitors, Zhejiang Wenzhou, targets its product to pubic bath houses, and does not compete in the pharmaeutical distribution segments in which AXM sells Weifukang. Ying Kou Biochemical Pharmaceutical Factory's main business focus is its bulk bioprocessing business. Their herbal antiseptic product is a minor line. Our largest competitor for both Cefaxlin Capsules and Norfloxacin Capsules is Yanfeng Pharmaceutical in Shenyang. As a company in the same city, they are considered to be a direct competitor. Yanfeng Pharmaceutical Company is a recently privatized State Owned Enterprise They employ approximately 400 persons. Their sales territory focus is in Shenyang city and although market share information is not available we consider Yanfeng Pharmaceutical Company to be a major competitor.

INDUSTRY TAXES AND COSTS

The Chinese government currently imposes a sales tariff of approximately 9.6% on imported pharmaceuticals, plus a 17% value-added tax charge, customs clearing charges and drug inspection costs. The prices of imported pharmaceuticals are further inflated by high distribution costs and hospital mark-ups. The retail prices paid by hospitals can be as much as 10 times higher than the manufacturer's price. In addition, only those drugs that appear on the provincial and municipal reimbursement lists are covered by the national medical insurance system, which naturally favors locally-manufactured products. Since according to IMS Market Research Consulting (Shanghai) in its report titled "IMS Market Research Consulting (Shanghai), Market Prognosis Asia, 2003-2007, China Report" approximately 80% of all drugs sold in The Peoples Republic of China are sold through hospital pharmacies, exclusion from these lists may result in huge losses in sales. We believe Chinese industry regulators are concerned about the surging drug costs for the national health care system, which accounts for about 70% of the total healthcare expenditure. Consequently, the government has initiated new plans to separate medical consulting from

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medical prescription. The State Development Planning Commission of The Peoples Republic of China has announced its intention to re-examine the pricing of drugs in The Peoples Republic of China, as well as to decrease the cost of "over-supplied drugs," according to the IMS Market Prognosis Asia 2003-2004, China Report.

RESEARCH AND DEVELOPMENT

Our research and development activities have focused on quality and laboratory testing of compounds developed by others, and administration of the testing process and the negotiations for rights to the compounds. In this effort, we have developed working relationships with Shenyang Medical University and the Liaoning Research Institute for Traditional Chinese Medicine and Beijing Shiehe Medical University. As a result of our cooperative work with our research partners, we have expended only a nominal amount (relating only to analytical testing, travel and meeting expenses) on research and development during the year ended December 31, 2002.

EMPLOYEES

At June 25, 2004, we had two employees in our U.S.-based headquarters and 35 full-time employees at our facilities located in The Peoples Republic of China. Until our new factory is completed we intend to hire additional employees on a part-time or independent contractor basis in connection with certain projects in The Peoples Republic of China. We also intend to hire up to two additional employees to serve in administrative positions at our U.S.-based headquarters in the near future.

Once our new factory is completed, our forecast for staffing includes:

o approximately 200 full time employees in manufacturing, management administration and marketing/sales
o approximately 10 independent contractors assigned to market research and market analysis
o approximately 90 sales persons assigned to in-store promotion at the retail pharmacy level
o approximately 10 medical doctors employed part time to write technical briefs for products and diseases of interest

None of our current employees is represented by a labor union and we consider our relationships with our employees to be good.

REGULATORY ENVIRONMENT

Effect of Government Regulation

The modernization of regulations for the pharmaceutical industry is relatively new in the The Peoples Republic of China and the manner and extent to which it is regulated will continue to evolve. As a pharmaceutical company, we are subject to the Pharmaceutical Administrative Law, which governs the licensing, manufacture, marketing and distribution of pharmaceutical products in the Peoples Republic China for the and sets penalty provisions for violations of provisions of the Pharmaceutical Administrative Law. In addition as a Wholly Foreign Owned Enterprise we are subject to the Foreign Company provisions of the Company Law of the Peoples Republic of China, which governs the conduct of our wholly owned subsidiary, AXM Shenyang and its officers and directors. Changes in these laws or new interpretations of existing laws may have a significant impact on our methods and our costs of doing business.

Additionally, we will be subject to varying degrees of regulation and permitting by governmental agencies in The Peoples Republic of China. For example, in 1999, the State Food and Drug Administration of The Peoples Republic of China set up an administrative system for the classification of prescription and over-the-counter drugs. Since then, the State Food and Drug Administration has issued a series of guidelines on interpretation of the new classification system in such areas as labeling, usage instructions and packaging of over-the-counter products.

Recently, the State Food and Drug Administration implemented new Good Manufacturing Practices guidelines for licensing of pharmaceutical products. We will be required to comply with these new guidelines by December 31, 2004, in order for our current licenses to be renewed. Since we are constructing our new factory in Shenyang to meet more stringent U.S. Good Manufacturing Practices requirements, we believe that we will satisfy the new guidelines and that our current licenses will be renewed. Failure to satisfy these new guidelines would have a material adverse effect our business.

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In 2003, the government implemented a new regulatory regime for registration of prescription and over the counter pharmaceutical products. The legislation requires a change in registration status from provincial government approval to national government approval. We do not anticipate difficulties with this transition, however any delays in government review as a result of the recent changes, could impact our ability to gain approval for new or existing products.

There can be no assurance that future regulatory, judicial and legislative changes will not have a material adverse effect on our business, that regulators or third parties will not raise material issues with regard to our business and operations or our compliance or non-compliance with applicable regulations or that any changes in applicable laws or regulations will not have a material adverse effect on AXM Pharma.

Compliance With Environmental Laws

We are subject to the environmental laws of The Peoples Republic of China and its local governments. However, because we currently outsource manufacturing of our proprietary licensed products, we do not incur significant expense related to compliance with such laws nor do we expect to be affected significantly by compliance with such laws.

Compliance with Registered Capital Requirements

Pursuant to the Company Law of The Peoples Republic of China, we are required to contribute a certain amount of "registered capital" to our wholly owned subsidiary, AXM Shenyang. AXM Shenyang's current registered capital requirement is US $10,000,000, of which we have contributed $8,579,181. Since AXM Shenyang is classified as a Wholly Foreign Owned Enterprise, pursuant to the Law on Foreign Capital Enterprises of The Peoples Republic of China, as well as its implementation rules (also known of the "Wholly Foreign Owned Enterprise Law"), we were not required to contribute all of our registered capital at the time AXM Shenyang was issued its business license. We are, however, expected to fully satisfy this registered capital requirement within a reasonable time period. We plan to satisfy this requirement through the completion of our new factory in Shenyang, the value of which will exceed the current shortfall in registered capital. Since we have been informed by our legal counsel in The Peoples Republic of China that they are not aware of any instance where the business license of a Wholly Foreign Owned Enterprise has been revoked due to failure to satisfy the registered capital requirement within a stipulated time period when most of its registered capital has been contributed, we do not believe that the current shortfall presents material risk to our business in The Peoples Republic of China. Moreover, we currently have sufficient funds available to satisfy the registered capital requirement if necessary. However, our management has determined that we will only contribute the funds to AXM Shenyang as they are needed to accomplish construction of the new factory or for other valid corporate purposes in The Peoples Republic of China. In February and March 2004, we transferred an additional $1,500,000 to AXM Shenyang, which, once the appropriate regulatory authorities accept it, will fully satisfy AXM Shenyang's registered capital requirement.

CORPORATE HISTORY

We were incorporated under the laws of the State of Nevada on June 30, 1999, with the name Wholesale on the Net, Inc. Our original business purpose was to develop and sell business products over the Internet. In April 2001, we entered into a stock purchase agreement to acquire certain trademarks and control of a hotel and changed our named to Wickliffe International Corporation. We planned to operate hotels and resorts under the mark "Wickliffe." We never completed the planned stock purchase agreement.

In April 2001, we began searching for hospitality properties to acquire. However, because of the deteriorating market, in January 2002, we determined that we would search for an ongoing business that we could purchase solely for stock rather than having to raise capital to offer cash for an existing business enterprise. On December 12, 2002, we entered into a share exchange agreement to acquire Werke Pharmaceuticals, Inc., together with its wholly-owned subsidiary AXM Shenyang. The transaction contemplated by our share exchange agreement with the shareholders of Werke Pharmaceuticals, Inc. closed on March 14, 2003, at which time Werke Pharmaceuticals, Inc. became our wholly-owned subsidiary and the shareholders of Werke Pharmaceuticals, Inc.

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acquired approximately 88.89% of our voting stock. In connection with such acquisition , we commenced operations in our current line of business and changed our name to AXM Pharma

DESCRIPTION OF PROPERTY

Our corporate and United States offices are located at 3960 Howard Hughes Parkway, Suite 500, Las Vegas, Nevada. The current rent for these premises is $200.00 per month. Our lease expires on February 28, 2005. Our United States marketing office is located at 4695 McArthur Court, 11th Floor, Newport Beach, California 92660. The current rent for these premises is $2,647.94 per month. Our lease expires in September 30, 2004.

Our principal administrative, sales and marketing facilities are located at No. F.3004 Sankei Torch Bldg, 262A Shifu Road, Shenyang City, Liaoning Province, The People's Republic of The Peoples Republic of China. The current rent for these facilities is US$2,916.66 per month and our lease expires in October 2007.