SecProbe.io

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Mail Stop 3561
								September 7, 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
		Form 10-QSB for the Quarterly Period Ended June 30, 2005
		File No. 1-14791

Dear Mr. Tsaparas:

      We have reviewed your response letter dated August 19, 2005
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.  Where
indicated, we think you should revise your filings in response to
these comments.  If you disagree, we will consider your
explanation
as to why our comments are inapplicable or a revision is
unnecessary.
Please be as detailed as necessary in your explanations.

	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.

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

Consolidated Statements of Operations, page F-4

1.	We have reviewed your response to our prior comment number 2.
Please tell us where you record your 33% minority interest in RECO
in
your statement of operations or otherwise confirm that you have
stopped recording losses on your investment because the carrying
amount has been reduced to 0.  If so, in future filings, you
should
disclose this fact.

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

a. Organization, page F-12

2. We have reviewed your response to our prior comment number 5.
It
appears that you should not have recognized a gain on the exchange
of
your investments in Sunspring, Inc. and RECO for the common and
preferred stock of Sun Power Corporation since it was subject to a
mutual cancellation period.  Please revise your financial
statements
to reverse the $64,573 gain you recognized in 2001.

3. Additionally, please provide us with the following additional
information separately for both your investments in Sunspring,
Inc.
and Renewable Energy Corporation (RECO):

* The amount and date of your initial investment along with the
amounts and dates of each subsequent investment. Indicate the
cumulative percentage of ownership in each instance.

* The amount of net income / (loss) for each year from the date of
investment through December 31, 2004 or the date of
deconsolidation
for RECO.

* The dates and amounts of all advances.

* Please provide the above information in a rollforward schedule
which identifies the beginning balance, changes resulting from
additional advances, investments, net income / (loss) and ending
balance.

* Tell us if Sunspring or RECO conducted any operations from
November
26, 2001 through December 30, 2002, and if so, how you accounted
for
these results of operations.

4. We note your response to our prior comment number 7.  Tell us
why
RECO, a consolidated subsidiary, would have suspended or
unrecognized
losses subject to recapture which resulted in a gain upon
deconsolidation.  This comment also applies to your like
disclosure
regarding the recapture of losses for Sunspring, Inc..

Form 10-QSB for the Quarterly Period Ended June 30, 2005

Interim Consolidated Balance Sheets, page 4

5. We note that you have revised your December 31, 2004 balance
sheet
presented in your recently filed Form 10-Q.  You have also
indicated
in your August 19, 2005 responses to our prior comment numbers 1,
2
and 8 that you intend to amend your Form 10-KSB for the year ended
December 31, 2004.  Upon the conclusion of our review, in addition
to
amending your 2004 Form 10-KSB, we would expect you to amend your
most recent Form 10-Q to disclose these facts and label your
statement of operations and balance sheet for the year ended
December
31, 2004 as "restated."  Your disclosure should include the
resulting
effects of your restatement on previously reported financial
statements.  Refer to paragraph 26 of APB No. 9, Reporting the
Results of Operations or paragraph 26 of SFAS No. 154, Accounting
Changes and Error Corrections.

Interim Consolidated Statements of Cash Flows (Unaudited), page 6

6. We note your presentation of $50,000 of cash paid for mining
and
mineral rights in the investing activities section of your interim
consolidated statement of cash flows for the six-month period
ended
June 30, 2005, representing the return in cash of your $50,000
deposit on mining and mineral rights.  We also note your
disclosure
in Note 9 that you have collected $25,000 as of June 30, 2005 with
$25,000 remaining uncollected.  Please revise your filing to
correct
this inconsistency.

* * * * *

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.

	You may contact Scott Ruggiero at (202) 551-3331 if you have
questions regarding this comment 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
September 7, 2005
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