SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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July 8, 2005

Mr. John Nohren
Chairman and Treasurer
Innova Pure Water, Inc.
13130 56th Court
Clearwater, FL  33760

RE:  	Form 8-K Item 4.01 filed July 7, 2005
	File # 0-29746

Dear Mr. Nohren:

We have reviewed your filing and have the following comments.
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 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 filing.
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 number
listed
at the end of this letter.

1. You disclose that a copy of your former accountant`s letter is
included as an exhibit to this filing.  However, no exhibits were
filed with this Form 8-K.  Please file a letter from your former
accountant, indicating whether or not they agree with your
disclosures in the Form 8-K.

*****

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 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 file your response via EDGAR in response to these comments
within 5 business days of the date of this letter.  Please note
that
if you require longer than 5 business days to respond, you should
contact the staff immediately to request additional time.  You may
wish to provide us with marked copies of each amended filing to
expedite our review.  Direct any questions regarding the above to
the
undersigned at (202) 551-3866.

Sincerely,

Jeffrey Gordon
Staff Accountant
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John Nohren
Chairman and Treasurer
July 8, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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