SecProbe.io

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Mail Stop 6010

								August 10, 2005

Louis L. Knickerbocker
Chief Executive Officer
RG Global Lifestyles. Inc.
17751 Mitchell Avenue
Irvine, CA 92614

	Re:	RG Global Lifestyles. Inc.
		Schedule 14A
		Filed July 22, 2005
		File No. 000-25488

Dear Mr. Knickerbocker:

	We have reviewed your filing and have the following 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.

SCHEDULE 14A

Directors, Nominees for Directors and Officers, page 4

1. Please revise the discussion of each officer and director to
clarify how long each individual has served in his current
position
and how long he has been employed by the company or any of its
predecessors.  We note the disclosure of the term of office in the
table on page 4; however, many of these individuals are identified
as
officers and directors in your Forms 10-K going back as far as the
year ended December 31, 2001.

2. We note that some of your executive officers have additional
employment.  Please revise the discussion of the experience of
each of
these individuals to disclose the amount of time they devote to
your
operations.

Compensation of Officers and Directors, page 7

3. We note the table differs from the table included on page 15 of
your Form 10-KSB filed on June 29, 2005.  For example, the Form
10-KSB
discloses Mr. Hitchcock`s salary as $9,000 and his stock
compensation
at 280,000 shares, while the proxy statement discloses his salary
as
$36,000 and his stock compensation at 180,000 shares.  It appears
the
table in the proxy statement is the table for the year ended March
31,
2004 rather than March 31, 2005.  Please revise your proxy
statement
to provide the required salary information for the year ended
March
31, 2005.

Audit Committee, page 7

4. Since Mr. Koontz is a member of the audit committee, please
provide
the information required by Item 401(a) of Regulation S-B.  Also,
if
Mr. Koontz is not a director, please disclose the compensation
arrangements you have with Mr. Koontz.

5. We note the statement that the Chief Operations Officer is a
member
of the audit committee.  However, Grant King, who is identified on
page 4 as the COO, is not listed at the end of this paragraph, nor
is
he listed at the end of the Audit Committee Report on page 8.
Please
revise to clarify.

6. We note your statement that the $300,000 paid to PT Pacific for
the
rights to use PT Pacific`s permits was the fair market value.
Please
explain how it was determined that this was fair market value.

Proposal Number 2, page 9

7. Please state the reasons for the proposed amendment to increase
the
number of directors.  See Item 19 of Schedule 14A.

8. Also, please revise to disclose when the additional director
positions will be filled and how individuals will be selected to
fill
these positions.

Proposal No. 4

Tax Fees, page 10

9. We note Beckstead was utilized for tax services during the last
two
fiscal years.  Please disclose the aggregate fees billed in each
of
the two years for tax compliance, tax advice, and tax planning.
See
Item 9(e)(3) of Schedule 14A.

Proposal Number 5, page 11

10. Please identify every addition, deletion, or revision that
will be
made to the bylaws if the proposed amendment is approved.  Explain
the
reasons for and effect of each alteration.  See Item 19 of
Schedule
14A.

Proxy Card, page 35

11. We note the statement on page 12 that the proxies will have
the
authority to vote the shareholders` shares on any other matters
that
are properly presented for a vote at the meeting.  Please include
this
item as a proposal on the proxy card.

*	*	*

	As appropriate, please amend your filing 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 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 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 disclosure,
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
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments 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.

	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 filing or in response
to
our comments on your filing.

	Please contact Greg Belliston at (202) 551-3861 or me at
(202)
551-3715 with any questions.

								Sincerely,

								Jeffrey Riedler
								Assistant Director

cc:	Ruba R. Qashu
	Oswald & Yap
	16148 Sand Canyon Avenue
	Irvine, California, 92618
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Louis L. Knickerbocker
RG Global Lifestyles. Inc.
August 10, 2005
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