SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
								July 7, 2005

Mr. Albert Figueroa
Treasurer & Principal Accounting Officer
Largo Vista Group, Ltd.
4570 Campus Drive
Newport Beach, California  92660

	Re:	Largo Vista Group, Ltd.
		Form 10-KSB for Fiscal Year Ended December 31, 2004
      Filed April 18, 2005
		Form 10-QSB for Fiscal Quarter Ended March 31, 2005
      Filed May 11, 2005
		File No. 000-30426

Dear Mr. Figueroa:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments. Where indicated, we think you should
revise your documents.  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 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 disclosures in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Description of Business, page 3

1. We note your disclosure of the February 2002 and May 2003
agreements with the Zunyi Municipal Government to design and
install
the liquid petroleum gas (LPG) pipeline systems in residential
areas
in the city of Zunyi, China.  Please expand your disclosure to
describe the LPG pipeline systems, specifically the configuration
and
method of operation, and the extent to which you rely on third
parties to perform the installations.  The specific services you
provided in the design, installation and operation of the pipeline
systems should be clear.

2. We note your disclosure of the March 2005 agreement with
Shanghai
Offshore Oil Group.  Please expand your disclosure to describe
more
fully the extent of your involvement in transporting fuel oil from
Russia to China, and to the end-users in China.  Clarify whether
you
will be assuming the role of an agent, earning a fee for delivery
services, or that of a reseller or principal.  The specific
services
that you are required to provide under the agreement should be
stated.

You also disclose that you will be guaranteed a minimum of $2
profit
per metric ton delivered.  Disclose the circumstances under which
the
unit profit will vary, including the range and showing correlation
with volume or other relevant parameters.  Additionally,
disclosing
your expectations of the actual volumes and amounts you would
deliver
and earn over the term of the agreement would be appropriate.

On a related point, the $1.2 billion contract value that you
disclose, based on the market value of the maximum amount of
product
that could be delivered under the agreement, appears to be
unrelated
to the fee structure that you describe.  Unless you are able to
demonstrate the relevance of this figure, in terms of your revenue
generating prospects, removing this reference may be necessary to
avoid the possibility that readers will attribute a greater value
to
your arrangement than is warranted.

Management`s Discussion and Analysis, page 13

Revenue Recognition, page 15

3. We note your disclosure that under your agreements with the
Zunyi
Municipal Government, the Government pays 50 percent of the total
contracted installation price, and you have to collect the
remaining
50 percent directly from residential customers.  Please clarify in
your disclosure how the residential customers become your
customers
(describe the mechanism by which the fees are collected), given
that
they are not contractually obligated under your agreements with
the
Zunyi Municipal Government.

Results of Operations, page 15

4. Clarify in your disclosure the extent of your 2004 and 2003
revenues from the Zunyi facility that were attributable to LPG
sales
versus LPG pipeline system design, installation and operation
services.

Controls and Procedures, page 41

5. We note that you evaluated and concluded on the effectiveness
of
your disclosure controls and procedures within 90 days prior to
the
date of your report.  Please comply with the guidance in Item 307
of
Regulation S-K, under which you are required to perform this
evaluation as of the end of the period covered by your report.

Report of Independent Registered Certified Public Accounting Firm,
page F-3

6. Tell us which affiliate of your independent auditor, who is
based
in McLean, Virginia, conducted the audit of your operations in
China.
Please ask your auditor to advise us of the extent of services
provided by staff assigned to its office in Virginia, compared to
that of its affiliate overseas.

Certifications, Exhibits 31.1 and 31.2

7. Please revise your certifications as necessary, and to the
extent
appropriate, to comply with the requirements of Item 601(b)(31) of
Regulation S-B.

Closing Comments

       As appropriate, please amend your filings and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosures in the filings to be certain that the
filings include 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 disclosures, 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
disclosures in the filings;
* staff comments or changes to disclosures in response to staff
comments do not foreclose the Commission 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 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 filings or
in
response to our comments on your filings.

	You may contact Lily Dang at (202) 551-3867 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3686 with any other
questions.

								Sincerely,

								Karl Hiller
								Branch Chief
??

??

??

??

Mr. Albert Figueroa
Largo Vista Group, Ltd.
July 7, 2005
Page 1

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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

</TEXT>
</DOCUMENT>