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Black Mountain Capital Corp

      Reply
      Attention of:

      Stewart
      L. Muglich

      Our
      File No.:

      6369
      035

      Direct
      Line:

      (604)
      692-3023

      Email:

      smuglich@sangramoller.com

November
3, 2005

VIA
EDGAR, FACSIMILE AND COURIER

SECURITIES
AND EXCHANGE COMMISSION

100 F
Street, N.E., Stop 0308

Washington,
D.C. 20549-0308

Attention: Michael
Moran, Branch Chief

Mail
Stop 0308

Dear
Sirs/Mesdames:

Re: Black
Mountain Capital Corporation (the "Company"), Form 20-F for the Fiscal Year
Ended December 31, 2004 (the "Form 20-F"), Form 6-K for the Fiscal Quarter Ended
March 31, 2005 (the "Form 6-K"), File No. 0-13966

We act as
counsel for the Company and write in connection with the second comment letter
dated October 18, 2005 (the "Comment Letter") from the Securities and
Exchange Commission (the "Commission") to the Company on the Company's Form 20-F
and Form 6-K. On behalf of the Company, we provide the following responses to
your comments. For your ease of reference, we have set out below, in italics,
the comments contained in the Comment Letter, with the Company's responses
following each comment.

Form
20-F for the Fiscal Year Ended December 31, 2004

      1.

      In
      your response to comments 1, 2 and 10, you state, "We note your comment".
      Please confirm that you will revise your disclosure in future filings and
      show us what your revisions will look
like.

1.    In future
filings the Company will breakdown revenue by category as follows:

Item 4.
Information on the Company

      REVENUE

      2005

      Securities

      •

      Royalties

      •

      Interest

      •

2.     In future
filings, the Company will disclose if the decrease in revenues represents a
trend in accordance with Item 5.D of Form 20-F under the heading "Item 5.
Operating and Financial Review and Prospects".

10.    In future
filings the Company will disclose operating leases as follows:

 Note
12.   Commitment

General and administrative costs include the following expenses:

      2005

      Consulting
      fees, salaries and benefits

      •

      Non-recoverable
      GST

      •

      Office
      and miscellaneous

      •

      Operating
      leases

      •

      Professional
      fees

      •

      Regulatory,
      transfer agent and shareholder

      communication

      •

    •

Note
4. Loan and Receivables, page 36

      2.

      We
      note your response to comment 8 in your letter dated September 21,
      2005. We are still unclear how you accounted for the difference between
      the fair value of the asset received and the fair value of the loan
      written down for the receipt of the common shares of a public U.S. company
      with a market value of $306,530 for a loan receivable previously written
      down during the 2002 fiscal year in the amount of $108,065. Please refer
      to paragraph 18 of the APB No. 29 in your
    response.

      During
      fiscal 2002, the Company wrote-off a loan it made to a Company that had
      filed for bankruptcy. During fiscal 2003, the Company received shares of a
      US listed company as settlement for the loan. The Company reported the
      recovery of $108,065, which represented the amount of the loan, as a gain
      on the income statement and as the cost base of the shares. The fair
      market value of the shares, as reported in the financial notes, was
      $306,530 for the year ending December 31, 2003. In reference to paragraph
      18 of APB No. 29, the Company recorded the cost of the shares received
      based upon the value of the asset they arose from as the shares of the US
      listed company were not trading at the time of
transfer.

We trust
the foregoing to be in order but should you have any questions or concerns,
please do not hesitate to contact the undersigned.

Yours
truly,

SANGRA
MOLLER LLP

Per:
/s/ Stewart L. Muglich

Stewart
L. Muglich

(New York
State Bar No. 098563)

SLM/tp

cc. Black
Mountain Capital Corporation

      Attention:
Tom S. Kusumoto

Securities and Exchange Commission, Stop 0308

      Attention:
Dave Irving