SecProbe.io

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                                                 March 16, 2005

via U.S. Mail							via facsimile

Mr. Robert Dinning						Mr. Dennis Brovarone
Director, Chief Financial Officer, Secretary			(303) 466-
4826
Apolo Gold Inc.
#1209-409 Granville St.
Vancouver, British Columbia V6C 1T2

Re:	Apolo Gold Inc.
		Schedule 14A filed on February 28, 2005
	File No. 0-27791

	Form 10-KSB for the year ended June 30, 2004
	Filed August 30, 2004
	File No. 0-27791

Forms 10-QSB for the quarters ended September 30, 2004 and
December
31, 2004
Filed November 12, 2004 and February 11, 2005

Dear Mr. Dinning:

      We have limited our review of your above Schedule 14A to
Proposals 3 and 4 and the above periodic reports to Items 307 and
308
of Regulation S-B, and have the following comments.

      Where indicated, we think you should revise your documents
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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not 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
filings.
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.

Schedule 14A

Proposal 3 - Amend the Articles of Incorporation to authorize a
Class
of Preferred Stock.

1. We note your statement that you have no specific plans at this
time for any of the actions you discuss for the preferred shares.
We
note also a recent press release in which you state that you will
seek shareholder approval for the creation and issuance of up to
25,000,000 preferred shares to acquire an Absolute Assignment from
Balmoral Companies of a 22% interest in an oil property.  Would
you
be able to complete this transaction with the preferred shares you
currently have?  If not, revise this section to describe your
plans
for the preferred stock.  In this regard, you would be required to
include all of the information required by Schedule 14A with
respect
to the acquisition.  Refer to Note A of Schedule 14A.

Proposal 4 - Approval of the Apolo Gold Inc., 2005 Directors and
Officers Stock Option Plan

2. Pursuant to Item 10 of Schedule 14A, please provide an equity
compensation plan table.

Forms 10-QSB

Controls and Procedures

3. Please provide the requisite disclosure in each Form 10-QSB
cited
above required by Items 307 and 308 of Regulation S-B.  We note
that
you include the requisite disclosure in your Form 10-KSB for the
year
ended June 30, 2004.  Also, ensure that you include this
disclosure
in all applicable future filings.
Closing Comments

      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 supplemental 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

      Direct any questions regarding this matter to Jason Wynn, at
(202) 824-5665, or in his absence, to Tangela Richter, Branch
Chief,
at (202) 942-1837.   Please send all correspondence to us at the
following ZIP code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

cc: 	J. Wynn
	T. Richter

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Apolo Gold Inc.
March XX, 2005
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

eFoodSafety.com, Inc.
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