SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 3561
								July 26, 2005
Mr. Peter Tsaparas
Chief Executive Officer
Solar Energy Limited
145-925 West Georgia Street
Vancouver, British Columbia  V6C 3L2
Canada

      Re:	Solar Energy Limited
		Form 10-KSB for the Fiscal Year Ended December 31, 2004
		File No. 1-14791

Dear Mr. Tsaparas

      We have reviewed your filing and have the following
comments.
We have limited our review only to your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Please be as detailed as necessary in
your explanations.  Where indicated, we think you should amend
your
filing 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.  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.

Consolidated Balance Sheets, page F-3

1. Please tell us the terms of your $176,667 other receivable
recorded at December 31, 2004.  Specifically, tell us when the
amount
is due and from whom, the interest rate, if any, and the status of
collection efforts.  Please confirm that the receivable is not due
from a related party as that term is defined in paragraph 1 of
SFAS
57.

Consolidated Statements of Operations, page F-4

2. Please explain to us the facts and circumstances surrounding
your
recognition of minority interest income of $1,238 and $66,969 for
the
years ended December 31, 2004 and 2003, respectively.
Specifically,
please tell us for which subsidiaries or investments the income
was
realized and provide us with any supporting calculations.

3. We note your presentation of your gain on investments of
$70,000
during the year ended December 31, 2003. Please tell us the facts
and
circumstances surrounding your recognition of this gain.
Specifically, tell us the nature of the investments sold, the
terms
of the sales agreement and consideration received and provide
supporting calculations, if any.

Notes to the Consolidated Financial Statements, page F-11

Note 1 - Summary of Significant Accounting Policies, page F-11

a.  Organization, page F-12

4. We note your disclosure related to your sale of 37% of RECO in
June 2000.  Please explain the basis for your conclusion that
minority interest of $162,800 and a gain of $17,200 should be
recorded in connection with this sale.  Please provide us with
supporting calculations and journal entries supporting your
financial
statement presentation.

5. We note your disclosure regarding your agreements with Sun
Power
Corporation involving your two subsidiaries, Sunspring, Inc. and
Renewable Energy Corporation (RECO).  You indicate that you used
the
equity method to account for your investment and recognized a gain
on
the exchange of Sunspring, Inc common stock for your interest in
Sun
Power Corporation.  Please tell us the basis in GAAP for
recognizing
a gain on this agreement and the amount of the gain recorded.

6. We also note your disclosure related to the $186,667 gain on
investments recorded during the year ended December 31, 2004
related
to the sale of your shares of Sun Power Corporation.  We have the
following comments:

* Tell us if Sun Power Corporation or any of its officers or
shareholders was or is a related party as defined in paragraph 1
of
SFAS 57.

* Explain to us why you retained 2,000,000 restricted common
shares
of Sun Power Corporation from the Sunspring, Inc. agreement.  Tell
us
if your entitlement to the common shares was contemplated as part
of
the original agreement, and if not, when and why these shares were
transferred to you.

* Confirm for us that you did not provide any service or other
consideration for the 2,000,000 common shares of Sun Power, Inc.

* Tell us what percentage ownership of Sun Power Corporation your
2,000,000 restricted common shares represented.

7. We note your disclosures related to the 33% ownership interest
that your subsidiary, REEL, holds in RECO.  Please provide us with
the following additional information related to your investment in
RECO:

* Please tell us why you did not present your interest in RECO as
an
investment on your December 31, 2004 balance sheet;

* Please tell us how much you received in consideration, if any,
for
the 200,000 shares of RECO issued to LARE resulting in your
current
33% ownership interest in RECO;

* Please tell us LARE`s total ownership interest in RECO prior to
and
after the issuance of the 200,000 shares.

* Please explain the facts and circumstances surrounding your
recognition of $56,138 in gain due to the recapture of prior year
losses resulting from your sale of 67% of your interest in RECO
and
provide us with any supporting calculations;

* Please tell us the amount of debt you forgave in connection with
your sale of RECO`s controlling interest; and

* Please clarify the timing of both the stock purchase agreement
and
the forgiveness of RECO`s debt.

Exhibits, page 25

8. It appears that you have not filed the consent from your
independent accountants to incorporate by reference your financial
statements into your previously filed registrations statements.
Please amend your filing to include the consent as exhibit 23.
Refer
to Item 601(b)(23) of Regulation S-B.

* * * * *

       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
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 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.

	You may contact Scott Ruggiero at (202) 551-3331 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3716 with any other
questions.

Sincerely,

William Choi
Branch Chief

Mr. Peter Tsaparas
Solar Energy Limited
July 26, 2005
Page 1

</TEXT>
</DOCUMENT>