SecProbe.io

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Mail Stop 0306

      May 11, 2005

Via U.S. Mail and Facsimile to (818) 623-1710

Martin Perellis
Chairman of the Board and Chief Financial Officer
Camera Platforms International, Inc.
10909 Vanowen Street
North Hollywood, California 91605

	Re:	Camera Platforms International, Inc.
		Form 10-K for the year ended December 31, 2004
		Filed March 24, 2005
Forms 10-Q for the periods ended March 31, 2004
      File No. 000-14675

Dear Mr. Perellis:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
documents 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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the year ended December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

1. Please revise to provide a discussion of critical accounting
policies, including valuation allowances on rental assets.  Refer
to
FR-60 and FR-72 for guidance. Please note that critical accounting
policy disclosure should provide insight about complex judgments
and
estimates that underlie the accounting policies you identify as
critical.  Disclosure that merely repeats basic accounting
policies
will not generally satisfy the objectives of the disclosure.

Liquidity and Capital Resources - Page 11

2. We note your discussion regarding the Company`s ability to
continue as a going concern.  Please revise Note 1 and MD&A to
provide more details of your specific plan of operations,
including,
plans to generate sufficient liquidity, financing needs and
expected
sources of this financing. The discussion should also contain
appropriate and prominent disclosure of your financial
difficulties
and viable plans to overcome these difficulties and resolve the
doubts about your continued existence.  Refer to FRC 607.02.

Financial Statements

Statements of Operations - Page 17

3. We note on page 25 that you sold equipment for a gain of
$177,000
in 2004 and you received insurance proceeds for stolen equipment
of
$165,000 in 2003.  We also note that both of these transactions
were
classified as non-operating income on the statement of operations.
Please revise to present the gain on sale in 2004 as operating
income
as required by paragraph 45 of SFAS 144 or tell us why you believe
your classification as non-operating income is appropriate.
Alternatively, if your disposal of the cranes in 2004 constitutes
discontinued operations under SFAS 144, please revise your
financial
statements to conform to the disclosure requirements of that
Statement.  Additionally, since the $165,000 gain during 2003 was
from insurance proceeds, please revise your description in future
filings to more accurately describe the transaction.

4. As a related matter, tell us why you did not file a Form 8-K
under
Item 2.01 to report the disposition of operating assets during
2004.
Note that under Item 2.01, for disposals or acquisitions of
assets, a
Form 8-K is required when the level of significance exceeds 10%.
The
significance of both acquisitions and dispositions of assets is
measured based on the registrant`s total equity in the net book
value
of such assets, or, if greater, the amount that the registrant
paid
to acquire the assets or received upon the disposal of the assets,
relative to the registrant`s total consolidated assets.  Refer to
SEC
Release No. 33-8400.

5. We note from Item 11 - Executive Compensation that no executive
officer received any compensation for 2004.  Please tell us
supplementally whether you have accrued all costs of doing
business
for all periods, including any services provided without charge as
required by SAB Topic 1.B.1.

Long Term Debt and Related Party Transactions - Page 26

6. We see your disclosure on page 26 that your revolving line of
credit matures in June 2005.  However, you have classified the
outstanding balance of $193,000 at December 31, 2004 as long-term
debt on your consolidated balance sheet.  Please revise to
classify
the debt as current or tell us why your current classification is
appropriate.

7. We note that DOOFF, LLC has notified you that you are in
"material
default under the terms of the loan agreement."  Please revise to
classify the debt as current or tell us why your current
classification is appropriate.  Refer to SFAS 78.

Item 9A.  Controls and Procedures - Page 30

8. We note your disclose that your principal executive officer and
principal financial officer have evaluated your disclosure
controls
and procedures as of a date within 90 days of the end of the
period.
Please amend your filing to disclose management`s conclusion
regarding the effectiveness of your disclosure controls and
procedures as of the end of the period covered by the annual
report.
Refer to Item 307 of Regulation S-K and Part II.F of Management`s
Reports on Internal Control over Financial Reporting and
Certification of Disclosure in Exchange Act Periodic Reports,
Release
No. 33-8238, available on our website at
www.sec.gov/rules/final/33-
8238.htm.

9. Please revise your disclosure concerning changes in your
internal
control over financial reporting to also indicate whether there
was
any change in your internal control over financial reporting that
occurred during the last fiscal quarter that has materially
affected
or is reasonably likely to materially affect your internal control
over financial reporting, consistent with the language used in
Item
308(c) of Regulation S-K as amended effective August 13, 2003.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your amendment that keys your
responses to our comments and provides any requested supplemental
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 responses to our
comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain 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 Traci Hornfeck, Staff Accountant, at (202)
824-
5565 or me at (202) 824-5264 if you have questions regarding these
comments.  In this regard, do not hesitate to contact Brian
Cascio,
Branch Chief, at (202) 942-1791.

							Sincerely,

							Lynn Dicker
							Reviewing Accountant

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Mr. Martin Perellis
Camera Platforms International, Inc.
May 11, 2005
Page 4

Mr. Martin Perellis
Camera Platforms International, Inc.
May 11, 2005
Page 2

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