SecProbe.io

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										August 1, 2005

Mail Stop 3561

Via US Mail and Facsimile

Mr. Scott Hawrelechko
Chief Executive Officer and Chief Financial Officer
Suite 1000, 10050-112 Street, 10th Floor
Edmonton, Alberta, Canada T5K 2J1

Re:	Myriad Entertainment & Resorts, Inc.
	Form 10-KSB for the year ended December 31, 2004
	Form 10-QSB for the period ended March 31, 2005
	Commission file #: 000-24789

Dear Mr. Hawrelechko:

We have reviewed your July 22, 2005 response letter and have the
following comments.  Please file an amended Form 10-KSB in
response to
our request for expanded or revised disclosure.  If you disagree,
we
will consider your explanation as to why our comments are
inapplicable
or a revision is unnecessary.  We also ask you to provide us with
supplemental information so we may better understand your
disclosure.
Please be as detailed as necessary in your explanation.  We look
forward to working with you in these respects and welcome any
questions you may have about any aspects of our review.

* * * * * * * * * * * * * * * * * * * * * * *

Form 10-KSB for the year ended December 31, 2004

Financial Statements

Statements of Operations

1. We note from your response to comment 2 that although there
have
been some activities regarding Myriad-Tunica`s operations, the
costs
have been borne by Myriad-Golf, an affiliate controlled by your
CEO.
Please tell us why you believe that the costs are appropriately
recorded as Myriad-Golf`s expenses rather than those of Myriad-
Tunica.
If the costs relate to obligations of Myriad-Tunica, they should
be
considered expenses of Myriad-Tunica because they have been paid
by
the principal shareholder and should be reflected in the financial
statements of the consolidated company as earnings (loss) in your
equity investment.  Please advise or revise your statements
accordingly.  See SAB Topic 5T.

Notes to the Financial Statements

Note 2.  Investment in Myriad World Resorts of Tunica, LLC

2. We note from your response to comment 7 that you evaluated your
investment in Myriad-Tunica for impairment, noting that you do not
believe the investment is impaired.  Please revise Note 2 to
include
the fact that you have evaluated the investment for impairment,
noting
that it was not impaired at December 31, 2004.

Note 7. Related Party Transactions

3. We note the disclosure added to Note 7 indicating that certain
accounting, administrative and management functions are being
provided
by Myriad-Golf, a related party, which has not historically
charged
the Company for these services. We also note from your response
that
the Company and Myriad-Golf have the same controlling shareholder.
Given this factor, we believe that the Company`s financial
statements
should be revised to reflect the fair value of the services
provided
by Myriad-Golf as an expense and a capital contribution in the
Company`s financial statements. Refer to the guidance outlined in
SAB
Topics 5:T and 1:B.1.

* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter that keys your responses to our comments
and
provides any requested supplemental information.

You may contact Claire Erlanger at 202-551-3301 or me at 202-551-
3813
if you have questions.

								Sincerely,

								Linda Cvrkel
								Branch Chief
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Mr. Scott Hawrelechko
Myriad Entertainment & Resorts, Inc.
August 1, 2005
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