SecProbe.io

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Mail Stop 4561

      July 25, 2005

Mr. Leslie I. Handler
President and Chief Financial Officer
Nova Communications Ltd.
1005 Terminal Way, Suite 110
Reno, Nevada  89502-2179

Re:	Nova Communications Ltd.
Form 10-KSB for the fiscal year ended December 31, 2004
      Form 10-QSB/A for the quarterly period ended March 31, 2005
      File No. 333-82608

Dear Mr. Handler:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise your document 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.

Form 10-KSB for the fiscal year ended December 31, 2004

Recent Sales of Unregistered Securities, page 6
1. We note your disclosure that you have issued 32 million shares
of
common stock to Mr. Owen during the fiscal year ended December 31,
2004.  Please clarify to us why these shares are not reported as
issued and outstanding on your balance sheet and why Mr. Owen`s
beneficial interests are not reported in Item 11 to your filing.
Additionally, please advise us how you have met the disclosure
requirements of paragraphs 40 and 41 of SFAS 128 as it relates to
the
issuance of these shares to Mr. Owen.  Further, please disclose
the
issuance of these shares within note 3 to the financial statements
in
an amended filing.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, pages 7 to 8
2. In light of your disclosure within note 2 to the financial
statements, operating losses incurred, your working capital
deficit
and net capital deficiency, please amend your filing to include a
discussion of your ability to satisfy cash requirements and
whether
you will have to raise additional funds in the next twelve months.
Reference is made to Item 303 of Regulation S-B.

Financial Statements

Convertible Notes Payable, page F-13
3. Please help us to understand what consideration you have given
to
separately valuing the beneficial conversion feature on your notes
payable, how you currently account for the beneficial conversion
feature and your basis in GAAP for this accounting treatment.  In
your response, please help us to understand the nature of the
conditional events that are required should a holder wish to
convert
to common stock.  Reference is made to EITF 98-5.

Exhibits 31 and 32
4. We note from the signatures on page 12 of your filing that Mr.
Arthur N. Robins serves as Chief Executive Officer.  Please help
us
to understand how you have met the requirements of Exchange Act
Rule
13a-14 without filing the appropriate certifications from Mr.
Arthur
N. Robins or amend your filing to include such certifications.

Form 10-QSB/A for the quarterly period ended March 31, 2005

Consolidated Statements of Operations, page 4

5. We note that revenues earned during the quarter are from the
sale
of marketing rights.  Please advise us of your revenue recognition
policy as it relates to these transactions citing any relevant
accounting literature. In addition, please highlight the terms of
the
transactions in your response.  Finally, please disclose your
revenue
recognition policy in future filings.

Consolidated Notes to Financial Statements

Note 4 - Equipment, page 8
6. Please describe to us the research and development equipment
purchased during the period.  Also, please explain how you intend
to
use the equipment and over what period you intend to use it.
Finally, advise us how you considered paragraph 11(a) of SFAS No.
2
in capitalizing the equipment.

	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
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
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 Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed 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.

	You may contact Howard Efron, Staff Accountant, at (202) 551-
3439 or me at (202) 551-3403 if you have questions regarding
comments
on the financial statements and related matters.

								Sincerely,

      Steven Jacobs
      Branch Chief

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Mr. Leslie Handler
Nova Communications Ltd.
July 25, 2005
Page 4

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