SecProbe.io

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Mail Stop 3561

								October 3, 2005

Charles Camorata
Chief Executive Officer
Skreem Entertainment Corporation
1301 Travis, #1200
Houston, Texas  77002

      Re:	Skreem Entertainment Corporation
		Amendment no. 4 to Form SB-2
      Filed September 19, 2005
		File No. 333-124563

Dear Mr. Camorata:

      We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document 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 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Summary, page 4
1. Please revise the first and last paragraphs of this page to
state
that the stock is being registered for "sale" by the selling
shareholders, not resale.  Revise the table in the selling
shareholder section accordingly.

Risk factors, page 6

The Company is subject to potential rescission liability from a
previous private stock offering, page 8
2. Please revise to specify that the amendment did not comply with
the requirements of the federal securities laws, and remove the
mitigating statement indicating that you believe you substantially
complied with the legal requirements of the securities laws.
Specifically disclose the time period during which those
purchasers
may seek rescission.

Selling Security Holders, page 10
3. Please tell us why you have included two column headings that
appear to relate to the same information:  (1) share amount before
offering and; (2) share amount owned before the resale offering.
In
your response, please confirm to us which offerings you are
referring
to in the column headings on page 10.
4. Please tell us why the tabular information assumes Mr. Martin
will
sell 25% of the shares he owns or controls, and tell us why you
include his resale in increments of 25%.

Notes to Consolidated Financial Statements

Note 6. Capital Transactions, page F-15
5. Please briefly describe for us the unrelated transaction
prompting
the return of 3.5 million shares to the treasury.

      As appropriate, please amend your registration statement in
response to these comments.  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 amendment and
responses
to our comments.

      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 Act
of
1933 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.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      Please contact Johanna Vega Losert, Attorney-Advisor, at
(202)
551-3325 or me at (202) 551-3814 with any other questions.

      Sincerely,

Sara W. Dunton
Attorney-Advisor

cc:  	Hank Vanderkam
	Corey Floyd
	via facsimile: 713-547-8910
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Charles Camorata
Skreem Entertainment Corporation
October 3, 2005
Page 2

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