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                        CLAUDIA J. ZAMAN ATTORNEY AT LAW
                              27430 Riverside Lane
                                Valencia CA 91354
                                 (661) 287-3772
                            (818) 475-1819 Facsimile

                               September 30, 2005

United States Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Mail Stop 0407
Washington, D.C.   20549

Attention: Linda Cvrkel, Branch Chief

      Re:   Crown Partners, Inc. (the "Company")
            Form 10-KB for the fiscal year ended December 31, 2004
            File No. 33-11986-LA

Dear Ms. Cvrkel:

      In response to your letter of June 30, 2005 regarding the above-referenced
issuer,  please be advised that the issuer is responding to the Staff's comments
in this letter.

FORM 10-KSB FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004

Item 6. Management's Discussion and Analysis or Plan of Operations, page 5

1.    Your  disclosure  merely  repeats  information  that is evident  from your
financial statements. In addition to reiterating the various amounts that appear
in the financial statements, please revise future filings to include an analysis
and  quantification  of the  particular  causes of changes in line items such as
revenues,  general and administrative  expenses and impairment.  When changes in
revenue and  expense  items are  attributable  to several  factors,  each factor
should be separately identified and quantified. See Item 303 of Regulation S-B.

RESPONSE: In the Company's future filings, an analysis and quantification of the
particular  causes of change in line items will be included pursuant to Item 303
of Regulation S-B.

<PAGE>

Liquidity and Capital Resources, page 6

2.    Please expand your disclosure in future filings  discuss the  consequences
to your operations if (for whatever reason) you are unable to raise capital.

RESPONSES:  In the Company's future filings, it will discuss the consequences to
its operations if the Company were unable to raise capital.

Financial Statements
Consolidated Statements of Operations, page 3

3.    Supplementally  advise us and expand the notes to the financial statements
in future filings to, of your impairment policy for long-lived assets, the facts
and circumstances  related to your $374,385  impairment charge recognized fiscal
year 2003, and the methodology used to determine the amount of the impairment.

RESPONSES:  The impairment charge recognized in fiscal year 2003 was a result of
predictions of future cash flows in relation to the assets impaired.  Management
believes  that  the  carrying  value of the  fixed  assets  was not  recoverable
resulting  in an  impairment  charge of  $374,385.  This  decrease in value is a
result of revenue continuing to fall short of predictions.

Policy to Be Added:

IMPAIRMENT  OF LONG-LIVED  ASSETS - The Company  reviews  long-lived  assets and
certain  identifiable  intangibles for impairment  whenever events or changes in
circumstances  indicate  that  the  carrying  amount  of an  asset  may  not  be
recoverable.  If the carrying  amount is not  recoverable  and the fair value is
less  than the  carrying  amount  of the  asset,  a loss is  recognized  for the
difference. Fair value is determined based on market quotes, if available, or is
based on valuation techniques.

Consolidated Statement of Stockholders' Equity, page 4

4.    Reference is made to the issuance of your common stock for services during
the year ended December 31, 2004. Supplementally tell us and revise the notes to
the financial statements in future filings to disclose, whether the value of the
transaction was based on the fair market value of your common shares given or on
the fair value of the  services  received.  See  paragraph 8 of SFAS No. 123 and
paragraph 18 of APB 29 for  guidance.  As part of your  response,  also indicate
whether the stock issued for cash was to an unrelated third party.

RESPONSE:  The value of the transaction for shares issued for services was based
upon the fair market value of the Company's common stock. In future filings, the
Company will revise its notes to its financial statements so that this is clear.
The stock issued for cash was issued to an unrelated third party.

<PAGE>

Consolidated Statements of Cash Flows, page 5
Note 1- Summary of Significant Accounting Policies, Nature of Business, page 6

5.    You disclose in Note 1 that your main  activities and source of income are
from daily trading in stock markets.  We also note from your  statements of cash
flows that you purchased and sold marketable  securities during fiscal year 2004
and your statements of operations indicates that you realized a $107,192 loss on
securities  during  fiscal year 2004. In this regard,  revise future  filings to
include the disclosure  required by paragraph 21(b) of SFAS 115 and clarify your
accounting  policy for  unrealized  and realized gains (losses) for your trading
securities using the guidance set forth in SFAS 115. In addition,  please revise
your  statements  of cash flows in future  filings  to  reflect  cash flows from
purchases  and sales of your  trading  securities  as cash flows from  operating
activities in accordance with paragraph 18 of SFAS 115.

RESPONSE:  The Company will revise its future  filings to include the disclosure
required by SFAS 115, paragraph 21(b) as well as revising its statements of cash
flows  to  reflect  the  cash  flows  from  the  purchase  and  sale of  trading
securities.

Note 1- Summary of Significant Accounting Policies, Revenue Recognition, Page 7

6.    Please expand your revenue  recognition  policy to clarify how your policy
relates to the nature of your  business  operations  during the two years  ended
December 31, 2004.

RESPONSE:  Crown recognizes  revenue when persuasive  evidence of an arrangement
exists,  delivery has  occurred,  the sales price is fixed or  determinable  and
collectibility is probable. These criteria are generally met at the time product
is shipped or services are  performed.  Shipping and handling costs are included
in cost of goods sold.

There  are  two  steps  that  need to be  completed  in  order  for a sale to be
considered  complete.  First,  the medical waste must be picked up by Crown from
various  customers.  Second Crown must process the medical  waste in  accordance
with  the  agreement  with  the  customer.  At the  point  both  procedures  are
completed, revenue is recognized.

Note 5- Advances, page 9

7.    Supplementally  advise us whether these advances are from a related party.
If so, please review your  disclosures in future filings include the disclosures
required by paragraph 2 of SFAS 57.

RESPONSE:  These  advances  are from  related  parties and future  filings  will
include the disclosures required by paragraph 2 of SFAS 57.

<PAGE>

FORM 10-QSB FOR THE QUARTERLY PERIOD ENDED MARCH 31, 2005

Financial Statements
Consolidated Statements of Operations, page 3

8.    Supplementally tell us and revise the notes to the financial statements in
future  filings  to  disclose,  the  facts  and  circumstances  related  to  the
forgiveness of debt in the amount of $19,206  recognized in the first quarter of
2004.  Please note that in the event that there is a related party  transaction,
the extinguishment transaction between related parties should be recognized as a
capital  transaction.  See  guidance  in  footnote 1 to APB  opinion  26.  Also,
supplementally  tell us where  the  forgiveness  of debt was  reflected  in your
statement  of  operations  for the fiscal year ended  December  31, 2004 and the
accounting literature that supports your accounting treatment.

RESPONSE:  In 2002,  the Company  borrowed  money and pledged  certain shares of
stock as security  with an unrelated  party.  When the Company was unable to pay
the loan back, the security was sold and the proceeds received were insufficient
to satisfy the loan  completely.  In 2004, the Company entered into a settlement
with the lender pursuant to which shares of the Company's  restricted stock were
issued to the lender in full and complete satisfaction of the debt. Based on the
fair market value of the shares  issued,  the amount  received by the lender was
less  than  the  lender  was  due,  resulting  in a  forgiveness  of  debt.  The
forgiveness of debt is noted in the Statement of Cash Flows.  The forgiveness of
debt  was  incorrectly  included  in  General  and  Administrative  expenses  of
$3,764,406.  In future  financial  statements the amount will be corrected and a
Reclassification footnote will be added to explain the change.

9.    Please revise future filings to present the line item,  interest  expense,
below the line item, operating income (loss).

RESPONSE:  The  Company's  future  filings will present the line item,  interest
expense and the below the line item, operating income (loss).

In connection with the Company's  responses to your comments,  please be advised
that the Company acknowledges the following:

      o     The Company is  responsible  for the  adequacy  and  accuracy of the
            disclosure in the filings;

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

      o     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.

<PAGE>

      Please contact the undersigned with any questions or comments.

                                                Sincerely,

                                                CLAUDIA J. ZAMAN ATTORNEY AT LAW

                                               /s/ Claudia Zaman
                                               ---------------------------------
                                               CLAUDIA J. ZAMAN

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