SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

                                        Ronald C. Touchard
                                        eWorldMedia Holdings, Inc.
                                        600 Anton Boulevard, 11th Floor
                                        Costa Mesa, CA  92626

                             November 28, 2005

Paul Fischer, Staff Attorney
Owen Pinkerton, Senior Counsel
United States Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

Re:  eWorldMedia Holdings, Inc.
     Preliminary Information Statement on Schedule 14C
     File No. 0-14047
     Filed on November 17, 2005

Dear Mr. Fischer and Mr. Pinkerton,

This letter is in response to your comment letter dated November 23, 2005
regarding our Preliminary Information Statement on Schedule 14C noted
above.  Our responses are as follows:

1. With regards to the disclosure on page 8 of the preliminary information
statement indicating that the company requires additional common stock in
order to satisfy entitlements of preferred shareholders who desire to
convert such shares to common stock, the authorization of additional common
shares is not necessary for the consummation of the purchase of Peaceful
Feet Shoeshine, Inc., as referenced in the From 8-K filed on October 3,
2005.  No common shares were granted in consideration of said acquisition;
only preferred shares were granted.  While all classes of the company's
preferred shares are convertible into common stock, the acquisition has
been consummated and is not contingent upon the increase of the Company's
authorized common shares. Therefore, we believe no revision of Item 14 of
Schedule 14A is required.

2. With regards to the press release dated May 23, 2005indicating that
eWorldMedia Holdings, Inc. intended to offer to buy 15,000 common shares
for consideration of $3.00 per share on a first come first serve basis, the
Company did not proceed with the buyback program.
            ---

The Registrant, eWorldMedia Holdings, Inc., hereby acknowledges the
following:

     -    The adequacy and accuracy of the disclosure in the filing is the
          responsibility of the registrant;
     -    The Registrant acknowledges that staff comment or changes in
          response to staff comment in the proposed disclosure in the
          preliminary information statement materials do not foreclose the
          Commission from taking any action with respect to the filing; and
     -    The Registrant also represents that staff comments may not be
          asserted as a defense in any proceeding initiated by the
          Commission or any person under the federal securities laws of the
          United States.

                                        Sincerely,

                                        Ronald C. Touchard,
                                        Chief Executive Officer
                                        eWorldMedia Holdings, Inc.

</TEXT>
</DOCUMENT>