SecProbe.io

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Mail Stop 7010

December 2, 2005

Via U.S. mail and facsimile

S. Matthew Schultz
Chairman of the Board
Left Right Marketing Technology, Inc.
585 West 500 South, #180
Bountiful, UT 84010

Re: 	Left Right Marketing Technology, Inc.
Preliminary Information Statement on Schedule 14C
Filed November 4, 2005
File No. 000-09047

Dear Mr. Schultz:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your filing in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General

1. We note that the EDGAR code under which you filed your Schedule
14C was PRE 14C.  It appears that the EDGAR code for the filing
should be PREM14C as the filing relates to a merger or
acquisition.
Please correct the EDGAR code by contacting EDGAR Filer Support at
(202) 551-8900.
2. Please be advised that you are not currently eligible to
incorporate by reference to your Exchange Act filings.  Please
revise
to disclose this information in your information statement.  In
addition, please revise your information statement to disclose the
information set forth in Annexes C, D and E.

Cover Page of Schedule 14C

3. We note that you have indicated no filing fee is required.  It
appears that a filing fee is required pursuant to Rule 0-11 under
the
Exchange Act.  Please revise the cover page to compute the filing
fee.  In addition, please pay that filing fee prior to filing your
next amendment.  See Rule 14c-5(g) under the Exchange Act.

Information Statement

4. Please revise the delivery date referenced on the cover page of
your information statement and under Item 1 of your information
statement.

Proposal One - Election of Director

5. Please revise Mr. Griffith`s biography to provide dates of
employment for each position identified and to provide his
employment
history for the past five years.  In addition, please identify
each
company referenced in his biography.

6. Please disclose the information required by Item 404(a) of
Regulation S-B.  See Item 7(b) of Schedule 14A.

7. Please disclose the information required by Item 7(d)(2)(ii) of
Schedule 14A.

8. Please disclose the information required by Item 306 of
Regulation
S-B.  See Item 7(d)(3)(i) of Schedule 14A.

9. Please disclose the information required by Item 7(f) of
Schedule
14A.

Proposal Two - Approval of the Agreement and Plan of
Reorganization...

10. Please advise us as to the Securities Act exemption upon which
you will rely to issue shares of your common stock to SGI
stockholders and the facts that make the exemption available.

11. Please remove your statement in the last sentence of the first
paragraph of this section that you are providing the information
for
informational purposes only to your security holders.
12. Please disclose how your company addressed or plan to address
conflicts of interest by your officers and directors, given that
Mr.
Schroeder, Mr. Schultz and Mr. Griffith were officers and
directors
of SGI and officers and directors of your company.

13. Please disclose the information required by Item 202 of
Regulation S-B.  See Item 11(b) of Schedule 14A.

14. Please disclose the general effects on your security holders
of
issuing shares of your common stock to SGI stockholders.  See Item
11(d) of Schedule 14A.

15. Please disclose the information required by Item 13(a) of
Schedule 14A.  See Item 11(e) of Schedule 14A.

16. Please provide the information required by Item 1001 of
Regulation M-A.  See Item 14(b)(1) of Schedule 14A.  Your
information
statement should begin with a summary term sheet.  See Instruction
2
to Item 1001 of Regulation M-A.

17. Please disclose the complete mailing address and telephone
number
of the principal executive offices of The Ultimate Poker League.
Refer to Item 14(b)(2) of Schedule 14A.

18. We note that you changed accountants on October 1, 2003.
Please
provide the information required by Item 304 of Regulation S-B.
Refer to Item 14(c)(i) of Schedule 14A and Item 14(i) of Form S-4.

Business Conducted

19. Please clarify the business currently conducted by The
Ultimate
Poker League.

20. Please identify the "well known national restaurant chain
which
owns a major casino to open in 2006 in Las Vegas."

21. Please clarify that you have no agreement or other
understanding
with any party to host the poker league or air your proposed
realty
television show.

Terms of the Transaction

22. We note the disclosure in the second paragraph of this
section.
Please describe in greater detail the reasons for engaging in the
proposed merger.

23. We note the disclosure in the last paragraph of this section.
Please describe in greater detail the federal tax consequences of
the
proposed merger.
Past Contacts, Transactions or Negotiations

24. Please provide the information required by Item 1005(b) of
Regulation M-A.  In this regard, the section should include a
"background of the merger" section that discusses in reasonable
detail the negotiations or material contacts between your company
and
SGI, including the identities of all parties involved, the date of
each meeting and the matters considered.  This section should also
discuss each meeting held by your board of directors regarding the
proposed merger and its final determination, including the
strategic
alternatives it considered and why they were not pursued.

Information About the Parties to the Agreement

25. Please disclose the information required by Item 14 of Form S-
4.
Please refer to Item 14(c)(1) of Schedule 14A.

26. We note the disclosure in the second paragraph of this
section.
Please disclose the information required by Item 201(b) of
Regulation
S-B.

27. Please remove your statement that you are providing certain
information to your stockholders for informational purposes only
set
forth in the first sentence of the third paragraph of this section
and in the first sentence of the first paragraph that immediately
follows the "Forward Looking Statements" section.

Background of the Industry

28. With respect to each source cited in this section, please
advise
us as to whether you funded or were otherwise affiliated with the
studies or reports.  Please also advise us as to whether you
believe
these studies or reports are the most recent materials on the
subject
by the authors and whether they are generally available to the
public, without payment of subscription or other fees.  Have these
studies or reports been published in widely circulated media or
among
members of the industry?  If so, please tell us when and where.

Poker League

29. Please explain the basis for the statements set forth in the
first, second and third sentences of this section.

Reality TV

30. Please explain the basis for your statement that the interest
in
the United States in reality based television concepts has been
"unwavering and growing."
31. Please explain more clearly the differences between the poker
tournaments currently aired on television and your concept of
"reality based television surrounding real live poker contest
play."
This is very confusing.

The Ultimate Poker League Contest

32. Please disclose the identities of the sponsors referenced in
the
second sentence of this section.  If you have not identified any
sponsors, please clearly disclose that you have no sponsors.

Competition

33. Please provide more detail here as to why you believe that
your
business format is unique.

34. Please explain how your prizes, including the $1,000,000 cash
prize disclosed in this document, would "exceed the expectations
of
contest players."

Government Regulation, Licensing and Taxation

35. Please discuss the basis for your statement that government
regulation in your industry is not probable.  We note your
disclosure
that contestants will compete for a cash prize of $1,000,000.
Please
address this in your response.

36. We note the disclosure in the second sentence of this section.
Please discuss the relevant laws of the other states in which you
intend to conduct your business.

37. It appears that certain of your employees will need to obtain
a
license from the Nevada Gaming Control Board.  Please discuss the
licensing requirements and in particular the relevant suitability
requirements.

Plan of Operation and Milestones

38. Please significantly revise this section to describe in
greater
detail your plan of operation for the next 12 months, including a
month-by-month analysis of your milestones.  Your current
disclosure
is too general.

39. Please discuss the timing for the commencement of your
operations
and when you anticipate generating revenue and being profitable.
In
this regard, please discuss any debt obligations you may incur to
finance your operations, as well as the anticipated costs of
operation.

40. Please discuss the costs associated with your company being a
public reporting company and the sources of funds you will use to
pay
these costs.

Procure Adequate Funding For Operations and the $1,000,000 grand
prize

41. Please describe your anticipated sources of financing for the
next 12 months of operation.  Please also provide a timeline
illustrating the points in time you will pursue each option and
the
order of preferences for your financing options.

Begin Negotiations With Advertising Partners

42. Please disclose your anticipated advertising costs over the
next
12 months.  In addition, please delete the last sentence of this
section.

Secure Contract Labor For Filming

43. We note your disclosure in the first sentence of this section.
It does not appear that the referenced experience is disclosed in
the
biographies of your executive officers and directors.  Please
revise
accordingly.

Item 5. Interests of Certain Persons in Matters to be Acted Upon

44. Please clarify where you state that Mr. Griffith serves as a
director of the company, given your proposal number 1.

Item 7. Directors and Executive Officers

45. We note the disclosure in the table regarding the dates served
by
Mr. Griffith.  It appears that in addition to being a director
nominee Mr. Griffith currently serves as your chief financial
officer.  Please revise accordingly.

Audit Committee and Financial Expert

46. We note your disclosure in the second paragraph of this
section.
Please clarify that the term "financial expert" is defined in Item
401(e)(2) of Regulation S-B.

47. Please disclose that Mr. Griffith will not be deemed an
independent director as he currently serves as your chief
financial
officer.

Item 8. Compensation of Directors and Executive Officers

48. Please revise the compensation table to include the
compensation
paid to Mr. Hall.  In this regard, we note the disclosure set
forth
in Item 10 of your Form 10-K for the fiscal year ended December
31,
2004.  See Item 402(a)(2)(i) of Regulation S-B.

49. Please disclose the information required by Items 402(c) and
(d)
of Regulation S-B with respect to Mr. Hall.

Compensation of Directors

50. Please clarify whether directors may participate under your
stock
compensation plan.

*	*	*	*

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
that is foiled on EDGAR with your amendment that keys your
responses
to our comments and provides any requested information.  Detailed
cover letters greatly facilitate our review.  Please understand
that
we may have additional comments after reviewing your amendment and
responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Exchange Act
and
that they have provided all information investors require for an
informed investment decision.  Since the company and its
management
are in possession of all facts relating to a company`s disclosure,
they are responsible for the accuracy and adequacy of the
disclosures
they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Please contact Andrew Schoeffler, Staff Attorney, at (202)
551-
3748 or, in his absence, Lesli Sheppard, Senior Staff Attorney, at
(202) 551-3708 with any questions.

Sincerely,

Pamela A. Long
Assistant Director
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S. Matthew Schultz
Left Right Marketing Technology, Inc.
December 2, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
  CORPORATION FINANCE

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