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SEC Correspondence Letter

INTERNATIONAL GEMINI TECHNOLOGY INC.

#208 – 828 Harbourside Drive

North Vancouver, BC V7P 3R9

Tel. 604.904.8481 Fax. 604.904.9431

September 22, 2005

    Securities and Exchange Commission

    Via Facsimile: 202-772-9220

    100 F Street, NE

    Washington, DC 20549-7010

Attention: Jennifer Goeken, Division of Corporate Finance

Dear Ms. Goeken:

Re: File No. 0-14740, Form 20-F filed June 30, 2005

Thank you for your letter dated September 13, 2005. For the purposes of this cover letter we will
respond using the numbering established in your letter.

1. The Company’s management team, affiliates and directors have special expertise in the
areas of due diligence, financial analysis and corporate finance strategy with respect to
emerging growth enterprises. Additionally, the Company retains Dockside Capital Group to
provide certain management functions and in so doing can also access its similar
expertise. From time-to-time the Company is approached, through referral, to provide
these services on a consulting basis. Thus the Company generates revenue by providing
these services. In Amendment No. 1 the “Item 5 Operating and Financial Review and
Prospects” under ‘Overview’ and ‘Results of Operations’ has been amended. The text of the
entire revised disclosure is reprinted below.

Overview

The Company‘s sole focus is on finding and completing a suitable
acquisition, or suitable acquisitions. This activity is largely
carried out by the directors and large shareholders at their expense.
The Company’s management team, affiliates and directors have special
expertise in the areas of due diligence, financial analysis and
corporate finance strategy with respect to emerging growth
enterprises. Additionally, the Company retains Dockside Capital Group
to provide certain management functions and in so doing can also
access its similar expertise. From time-to-time the Company is
approached, through referral, to provide these services on a
consulting basis. Thus the Company generates revenue by providing
these services. As these sources of revenue are not core to the
Company’s focus, the services are not actively marketed. Results can
fluctuate on the basis of postal rate
increases, or reductions in courier or long distance phone rates.

Results of Operations

The Company has shown modest losses for the past several years. These
losses result largely from having little or no revenue, rather than
having unusual expenses. This year the company elected to write down
the value of its passive investment, and this resulted in a loss that
was somewhat greater than usual. The expenses of the company are
almost completely related to satisfying regulatory requirements,
including the annual meeting, communication with shareholders; and
seeking and evaluating acquisition prospects for suitability and
ability to attract financing.

2. Our “Item 15 Controls and Procedures” were misstated. In Amendment No. 1 the Item 15
disclosure has been replaced in its entirety. The text of the revised disclosure is
reprinted below.

Within the 90-day period prior to the filing of this report (“Date of
Evaluation”), an evaluation was carried out under the supervision and
with the participation of the Company’s management, including the
Chief Executive Officer (“CEO”) and the acting Chief Accounting
Officer (“CAO”), of the effectiveness of our disclosure controls and
procedures. Based on that evaluation, the CEO and CAO have concluded
that the Company’s disclosure controls and procedures are effective to
ensure that information required to be disclosed by the Company in
reports that it files or submits under the Securities Exchange Act of
1934 is recorded, processed, summarized and reported within the time
periods specified in Securities and Exchange Commission rules and
forms.

The Company’s disclosure controls and procedures operate such that
important information flows to appropriate collection and disclosure
points in a timely manner and are effective to ensure that such
information is accumulated and communicated to the Company’s
management, and made known to the Company’s Chief Executive Officer
and Chief Accounting Officer, including the period when this Annual
Report on Form 20-F/A was prepared, as appropriate to allow timely
decision regarding the required disclosure.

There have been no significant changes in the Company’s internal
controls or the occurrence of events or other factors that could
significantly affect these controls, subsequent to the Date of
Evaluation. Nor have there been any corrective
actions with regard to significant deficiencies or material
weaknesses.

3. We will comply. In our Amendment No. 1 the Auditors’ Report of the former auditors
dated February 10, 2004 is included in the exhibits;

4. Note 2(e) has been revised. The entire text for the revised note is reprinted below
and is included in our Amendment No. 1

(e) Revenue recognition

The Company’s revenue in 2004 and 2003 consisted entirely of
consulting fees earned for providing due diligence, financial analysis
and corporate finance strategy to a company with a director in common.
(See Note 5.)

Revenue is recognized when the requirements as to performance for
transactions involving services are met, the amounts involved are
determinable and collection is reasonably assured.

5. Note 7 has been expanded to include a reconciliation of Accounts Receivable. The entire
text for the revised note is reprinted below and is included in our Amendment No. 1

    2004

    2003

    Accounts receivable per Balance Sheet

    $
    52,398

    $
    1,087

    Reclassify receivable for sale of Investment

    (30,000
    )

    —

    Sub-total

    $
    22,398

    $
    1,087

    Accounts Receivable brought forward

    1,087

    110,918

    Increase (Decrease) in Accounts receivable

    $
    21,311

    $
    (109,831
    )

    Increase (Decrease) in Accounts payable and
accrued liabilities

    44,542

    (70,605
    )

    Net Increase in non cash working capital

    $
    23,231

    39,226

The Company acknowledges that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in its
filings

    •

    SEC Staff comments or changes to disclosure in response to Staff comments do not
foreclose the SEC from taking any action with respect to the filings; and

    •

    the Company may not assert Staff comments as a defense in any proceeding initiated by
the SEC or any person under the federal securities laws of the United States.

We trust the above disclosure together with the filing of our Amendment No.1, filed concurrently,
will resolve your comments. Please contact the undersigned if additional comments arise.

Sincerely,

INTERNATIONAL GEMINI TECHNOLOGY INC.

Edward D. Ford

Director