SecProbe.io

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                               SWENSEN & ANDERSEN

                    A Professional Limited Liability Company

                                Attorneys at Law

James G. Swensen, Jr.                           136 South Main Street, Suite 318
email: jswensen@esalaw.com                            Salt Lake City, Utah 84101
       -------------------
also admitted in California
                                                         Telephone: 801-364-7500
                                                         Facsimile: 801-364-7510

                                  July 1, 2005

Mr. Jeff Jarmillo
Division of Corporate Finance
Securities and Exchange Commission
Washington, D.C. 20549

         Re:      ITEC Attractions, Inc.
                  Form 10-KSB for year ended December 31, 2004

Dear Mr. Jarmillo:

         This letter is in response to your letter dated May 31, 2005 containing
comments on the Form 10-KSB Annual Report of ITEC Attractions, Inc. ("Company")
for the year ended December 31, 2004. The responses contained herein are
numbered to correspond with the numbered paragraphs of your letter.

         As requested in your letter, we confirm on behalf of the Company, its
acknowledgment that:

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

         staff comments or changes to disclosure in response to staff comments
in the filings reviewed by the staff 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.

1. Item 6. Management's Discussion and Analysis or Plan of Operation.
   ------------------------------------------------------------------

         The Company proposes to amend its Form 10-KSB to restate Item 6 as
follows:

Item 6.  Management's Discussion and Analysis or Plan of Operation

                                       -1-
<PAGE>

         The following discussion and analysis should be read in conjunction
with the audited financial statements included elsewhere herein. Except for the
historical information contained herein, the matters discussed in this Annual
Report are forward-looking statements that involve a number of risks and
uncertainties. There are certain important factors and risks, including market
conditions, competitive factors, seasonality and other variations in the
entertainment industry and in Branson, Missouri specifically, the exhibition
life of films, our ability to retain managerial and other personnel, and the
other risks detailed from time to time in our SEC reports, including reports on
Form 10-KSB and Form 10-QSB, that could cause results to differ materially from
those anticipated by the statements made herein. Therefore, historical results
and percentage relationships will not necessarily be indicative of the operating
results of any future period.

         The Company operates an entertainment and eating facility in Branson,
Missouri and as such its product and service are discretionary expenditures
subject to the risks and factors attendant to the discretionary segment of the
economy.

         The Company's facility includes (i) an IMAX(R) giant screen theater,
three 35mm theaters and a live performance theater; (ii) a family dining
restaurant and food court with various fast food franchises; (iii) retail gift
operations; and (iv) retail space leased to third parties. The Company's
revenues are generated by these same categories or segments of its business,
ie., ticket sales, food sales, gift sales and rental income. The revenues
generated by each of these segments is primarily a function of the Company's
ability to attract tourist visits to its facility.

         The Company's customers consist primarily of tourist visitors to the
community of Branson and thus the Company's business is subject to the risks and
factors attendant to the vacation and travel industry. Branson must compete for
tourist visits with all other destination and resort locations. Branson, like
other resort locations, is subject to fluctuations in the tourism industry. And
within the universe of resort locations, Branson must compete with all other
resort locations for tourist visits. Branson has sought to identify itself with
and to appeal to the "family values" segment of the traveling and vacationing
public. The Company must not only consider its contribution to the overall draw
of Branson to the traveling and vacationing public, but must also consider its
relative appeal to tourist visitors of Branson in relation to all of the other
attractions at Branson.

         The Company's objectives with respect to each of its lines of business
are to keep the films it exhibits and the live entertainment it offers current
and fresh, provide quality food and service at its various eateries, stock
merchandise which is appealing to tourist visitors and lease space to retailers
that can contribute to the overall experience of the Company's facility.

Critical Accounting Policies and Estimates
------------------------------------------

         The discussion and analysis of our financial condition and results of
operations are based upon our financial statements, which have been prepared in
accordance with accounting principles generally accepted in the United States.
The preparation of these financial statements requires us to make estimates and
judgments that affect our reported assets, liabilities, revenues

                                       -2-

<PAGE>

and expenses. On an on-going basis, we evaluate our estimates, including those
related to revenue recognition, long-lived assets and deferred tax assets and
liabilities. We base our estimates on historical experience and on various other
assumptions that are believed to be reasonable under the circumstances. This
forms the basis of judgments about the carrying values of assets and liabilities
that are not readily apparent from other sources. Actual results may differ from
these estimates under different assumptions or conditions.

         We believe the following critical accounting policies and the related
judgments and estimates affect the preparation of our financial statements:

         Revenue Recognition. Revenue from the sale of admission tickets, retail
merchandise are recognized when earned, which is simultaneous with receipt of
payment. Returns of merchandise or refunds issued on admissions are recognized
at the time the refund is made. Sale of gift certificates are recorded as
deferred revenue until the certificate is redeemed. Revenue from lease of mall
space is recognized evenly over the term of the lease. Costs associated with
film exhibition and mall operations are expensed when incurred.

         Long-Lived Assets. At December 31, 2004 and December 31, 2003,
long-lived assets represented 77% and 79%, respectively, of the Company's total
assets. Long-lived assets consist of property and equipment. These assets are
depreciated or amortized over their estimated useful life. The Company
periodically reviews long-lived assets whenever adverse events or changes in
circumstances indicate the carrying value of such assets may not be recoverable.
In assessing recoverability, the Company must make assumptions regarding
estimated future cash flows and other factors to determine if an impairment loss
may exist, and, if so, estimate fair value. The Company also must estimate and
make assumptions regarding the useful lives assigned to its long-lived assets.
If these estimates, or their related assumptions, change in the future, the
Company may be required to record impairment losses or change the useful life
including accelerating depreciation or amortization for these assets.

         Deferred Tax Assets and Liabilities. Provision for income taxes is
based upon the Company's estimate of taxable income or loss for each respective
accounting period. An asset or liability is recognized for the deferred tax
consequences of temporary differences between the tax bases of assets and
liabilities and their reported amounts in the financial statements. These
temporary differences will result in taxable or deductible amounts in future
periods when the reported amounts of assets are recovered or liabilities are
settled. The Company regularly reviews its deferred tax assets to determine the
amount that is more likely than not to be realized. When this amount is less
than the deferred tax asset recorded, the Company records a valuation allowance
to reduce the asset to its estimated realizable value. If the Company determined
that it was not going to be able to fully realize its recorded deferred tax
assets, it would make an adjustment to the valuation allowance. This would
reduce net income in the period that the Company made its determination.
Similarly, if the Company realized that it was going to be able to fully realize
a deferred tax asset in excess of its net recorded value, net income would be
increased in the period that the Company made its determination.

                                       -3-

<PAGE>

         The Company also reviews its deferred tax liabilities on a regular
basis to determine that the amount recorded is adequate to cover the expected
reversal of temporary income tax liabilities. In the event that the amount
recorded was less than adequate, the deferred tax liability would be increased
to its estimated realizable value and net income would be decreased accordingly.
In the event that the deferred tax liability was determined to be overstated, it
would be reduced to its estimated realizable value and net income would increase
accordingly.

         The Company generally determines its effective tax rate by considering
the statutory federal income tax rate, the statutory state and local tax rates
(net of the federal income tax benefit) and any nondeductible expenses. This
rate could also be affected by increases or decreases to deferred tax assets or
liabilities as described above.

Liquidity and Capital Resources

         At December 31, 2004 the Company's working capital was $832,745
compared with a working capital of $614,398 at December 31, 2003. The Company's
current ratio at December 31, 2004 was 2.30 to 1.00. The increase in working
capital is attributable primarily to an increase in cash on hand.

         Net cash used in investing activities for the period ended December 31,
2004 totaled $173,347, which is comprised of capital expenditures for property
and equipment.

         Net cash used in financing activities for the period ended December 31,
2004 totaled $136,977, which represents principal payments on long-term debt.

         Stockholders' equity increased decreased from $2,135,671 at December
31, 2003 to $2,235,866 at December 31, 2004, reflecting the net income for 2004.

         As of December 31, 2004, the Company had borrowed $100,000 from Ms. Ann
Bluto, a director of the Company. The loan bears interest at prime plus 2%.
Proceeds from the loan were used to provide working capital for the Company.

         On July 24, 2000, the Company refinanced its existing line of credit
and existing long term debt with a new line of credit in the amount of $200,000
and a new term loan in the amount of $4,676,203. The additional proceeds of the
term loan were to refinance existing indebtedness and to finance the
construction of capital improvements. As of December 31, 2004, the principal
balance due on the term loan was $4,365,591. The line of credit was not renewed
in June 2003.

                                       -4-
<PAGE>

         As a condition of refinancing the existing long-term note, Bank of
America required the Company to enter into an interest rate swap to effectively
fix the interest rate on the Company's term note with the Bank which is due June
2013 at 10.4% through April 1, 2006. For the year ended December 31, 2004, the
Company recognized a gain of $276,452 on the interest rate swap compared to a
gain of $187,434 for the previous year. The increase in gain is attributable
primarily to the effects of rising interest rates and the shortening term of the
interest rate swap.

         Going forward, the Company expects to be able to finance its operations
and immediate capital requirements from currently available capital and cash
flow from operations.

Contractual Obligations and Commercial Commitments

         The following table summarizes our long-term debt, capital lease
obligations, and operating lease obligations as of December 31, 2004.
<TABLE>
<CAPTION>
                                                          Less than                                     After 5
                                                          ---------                                     -------
                                             Total          1 year       2-3 Years      4-5 Years        Years
                                             -----          ------       ---------      ---------        -----
<S>                                        <C>              <C>          <C>             <C>           <C>
Aggregate annual maturities of long-
  term debt                                $ 4,599,637      $212,866     $363,959        $304,244      $3,718,568

Payments on capital lease obligations           10,631         4,174        6,457              --              --

Future minimum rental payments
  under noncancellable operating
  leases                                     5,395,000       125,000       40,000          40,000       5,190,000
                                           -----------      --------     --------        --------      ----------

Totals                                     $10,005,268      $342,040     $410,416        $344,244      $8,908,568
</TABLE>

         The Company's operating leases as noted above represent its only
off-balance sheet arrangements. The Company leases land on which its facility is
constructed and its theater system. The Company has made advance rental payments
on the land and the theater system leases. The aggregate minimum rentals under
operating leases with non-cancelable terms of one year or more total $5,395,000.

Factors Affecting Future Operating Results

         The Company's future operating results will depend, in large part, upon
the Company's ability to maintain and to increase the market demand and presence
for its products and services and to operate profitably and efficiently. The
Company's ability to accomplish these objectives will depend on a number of
factors, including the following:

         o    Public perception of Branson, Missouri in general as a tourist
              destination;

                                       -5-

<PAGE>

         o    The Company's relative presence and competitive position in the
              Branson, Missouri market;

         o    The Company's ability to exhibit films and to provide live
              entertainment for which there is public acceptance;

         o    The Company's ability to deliver high quality food services;

         o    Emergence of any competing entertainment and food service
              facilities in Branson, Missouri;

         o    Success of the Company's efforts to expand and improve its
              entertainment and food offerings;

         o    Public perception of the Company and its products and services,
              including statements made by industry analysts or consumers and
              adverse publicity resulting from such statements or from
              litigation filed against the Company;

         o    Worldwide economic conditions, including overall travel and
              tourism;

         o    Ability of the Company to profitably and efficiently manage its