SecProbe.io

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Mail Stop 4561
									November 23, 2005

Mr. Neil Christiansen
Chief Executive Officer
Freedom Resources Enterprises, Inc.
901 East 7800 South
Midvale, UT 84047

      Re:	Freedom Resources Enterprises, Inc.
		Form 10-KSB/A for Fiscal Year Ended December 31, 2004
		Form 10-QSB/A for Fiscal Quarter Ended March 31, 2005,
Form 10-QSB for Fiscal Quarter Ended June 30, 2005
Form 10-QSB for Fiscal Quarter Ended September 30, 2005
		File No. 0-32735

Dear Mr. Christiansen:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  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 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
filings.
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.

Form 10-KSB/A for the Fiscal Year Ended December 31, 2004

Item 8A.  Controls and Procedures, page 7

1. Please represent to us that your officers carried out their
evaluation of disclosure controls and procedures as defined in
Exchange Act Rules 13a-15(e) and 15d-15(e), if true, and revise
your
disclosure in future filings to reflect the correct rule
references.

Item 13.  Exhibits and Reports on Form 8-K, page 10

2. Please revise the section 302 certification filed as exhibit
31.1
to reflect the language exactly as set forth in Item 601(b)(31) of
Regulation S-B, if such statements continue to be true considering
the revised wording and evaluation date as of the period end,
rather
than as of a date within 90 days of the filing.  Refer to
Management`s Report on Internal Control over Financial Reporting
and
Certification of Disclosure in Exchange Act Periodic Reports, SEC
Release No. 33-8238, available on our website at
<http://www.sec.gov/rules/final/33-8238.htm> for guidance.  Please
make conforming changes to the Forms 10-QSB for the quarters ended
March 31, 2005, June 30, 2005 and September 30, 2005.

Form 10-QSB/A for the Fiscal Quarter Ended March 31, 2005

Financial Statements

Unaudited Condensed Statements of Operations, page 7

3. We note your disclosure at Note 11 regarding the settlement of
debt in February 2005.  Please advise us of the facts and
circumstances resulting in the gain you recognized from the
settlement of debt.  Please include the nature of the accounts
payable and identify the creditor in your response.  Also,
describe
the terms under which you were released from these obligations.
Finally, explain how you considered paragraph 16 of SFAS 140 in
recognizing a gain on this transaction.

      As appropriate, please amend your filings 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 file your cover letter on EDGAR.
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 filings to be certain that the
filings include 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      You may contact Amanda Sledge, Staff Accountant, at (202)
551-
3473 or the undersigned at (202) 551-3403 if you have questions.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief
Mr. Neil Christiansen
Freedom Resources Enterprises, Inc.
November 23, 2005
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