SecProbe.io

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Mail Stop 0510

      March 22, 2005

via U.S. mail and facsimile

Mr. Ben Catalano
President
ThrillTime Entertainment International, Inc.
322-4585 Canada Way
Burnaby, British Columbia, V5G 4L6

	RE: Form 20-F for the fiscal year ended July 31, 2004
                   File No. 0-29328

Dear Mr. Catalano:

		We have reviewed your response letter dated February 24,
2005 and have the following additional comments.  If you disagree
with our comment, 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.

	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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 20-F FOR YEAR ENDED JULY 31, 2004

Item 5. Operating and Financial Review and Prospects

Critical Accounting Policies

1. We have reviewed your response to comment 2.  Please confirm
that
your response will be incorporated in future filings or provide us
with a supplemental response of your proposed prospective
disclosures.

Liquidity and Capital Resources

2. We have reviewed your response to comment 3.  Please confirm
that
your response will be incorporated in future filings or provide us
with a supplemental response of your proposed prospective
disclosures.  Please also incorporate where applicable the issues
discussed under Current Situation in your response to our comment
letter.

3. We have reviewed your response to comment 4.  Please confirm
that
your response will be incorporated in future filings or provide us
with a supplemental response of your proposed prospective
disclosures.

Tabular Disclosure of Contractual Obligations

4. We have reviewed your response to comment 5.  Please confirm
that
your response will be incorporated in future filings or provide us
with a supplemental response of your proposed prospective
disclosures.

Note 2.  (i) Revenue recognition

5. We have reviewed your response to comment 9.  Please revise
your
revenue classifications in future filings to distinguish between
sales of parts and other revenues and provide us with a
supplemental
response of your proposed prospective disclosures.

FORM 6-K FOR PERIOD ENDED JANUARY 31, 2005

Comments applicable to your interim filing

6. Please address the comments above in your interim filings as
well.

*    *    *    *

		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

       If you have any questions regarding these comments, please
direct them to Gus Rodriguez, Staff Accountant, at (202) 824-5524
or,
in his absence, Jeanne Baker, Assistant Chief Accountant, at (202)
942-1835 or, to the undersigned, at (202) 942-1774.

							Sincerely,

							Rufus Decker
							Accounting Branch Chief

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Mr. Ben Catalano
March 22, 2005
Page 3 of 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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