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August 4, 2005

Via Edgar (Private Correspondence)

and Via Telefax (202) 772-9202

Ms. Linda Cvrkel

Branch Chief

United States Securities & Exchange Commission

Washington, D.C. 20549

    Re:

    Las Vegas From Home.com Entertainment Inc.

    Form 20-F for the year ended December 31, 2004

    Commission File #: 000-29718

Dear Ms. Cvrkel:

Reference is made to your letter dated August 1, 2005, to which we are hereby responding as
follows:-

Form 20-F for the year ended December 31, 2004

Notes to the Financial Statements

Note 7. Equipment and Software Development, Page 50

    1.

    Please kindly note the following:-

    (a)

    The Company’s sole product is the Company’s gaming software which
includes certain card games (the “Company’s Gaming Software”);

    (b)

    The development of the Company’s Gaming Software is a continuous and
ongoing process (“Work-in-Progress”);

    (c)

    The Work-in-Progress consists of:-

    (i)

    changing the graphics of the Company’s Gaming Software in order
to meet changes in customer preferences;

    (ii)

    improving the scalability of the Company’s Gaming Software so as
to preferably eliminate, or failing that, to minimize the freezing of the card
games while players are actually playing online so as not to lose customers;

    (iii)

    improving the functionality of the Company’s Gaming Software so
that the card games preferably do not slow down, or failing that, the frequency
of the slow downs are reduced so that the Company does not lose its customers;

Las Vegas From Home.com Entertainment Inc.

6th Floor, 1199 West Hastings Street,

Vancouver, B.C. Canada V6E 3T5

Tel: (604) 681-0204 Fax: (604) 681-9428

Website: www.lvfh.com email: info@lvfh.com

Ms. Linda Cvrkel

Branch Chief

United States Securities & Exchange Commission

August 4th, 2005

Page 2

    (iv)

    increasing the player capacity of the Company’s Gaming Software
in order that the Company’s Gaming Software can accommodate any increase to the
customer base of the Company;

    (v)

    adding new features to the Company’s Gaming Software in order to
make it more appealing to the Company’s customers so that the Company may retain
its customer base and in order to attract new customers; and

    (vi)

    to modify the Company’s Gaming Software in order to meet the
requirements of the Company’s Licensees and/or customers.

    (d)

    Management of the Company is of the opinion that the Work-in-Progress
shall continue indefinitely in varying amounts;

    (e)

    The Company’s Gaming Software was determined to be technically feasible
and was generating revenues prior to January 1, 2004, nevertheless, Management took
the conservative approach of not capitalizing any direct or indirect software
development costs and expenses during the fiscal years ended December 31, 2002 and
2003. Only when Management of the Company felt confident in the sustainability of
generating revenues from the Company’s Gaming Software, then and only then did the
Company commence capitalizing the direct and indirect software development costs and
expenses as of January 1, 2004.

    (f)

    During fiscal 2004, the Company’s total payroll expense was Canadian
$2,864,355 which consists of the following:-

    (i)

    Contributed Surplus (Stock Based
Compensation Expense)

    Cdn$

    1,489,527

    (ii)

    Salaries for Administration

    193,050

    (iii)

    Salaries for Customer Service Employees

    163,915

    (iv)

    Salaries for Computer Programming,
Technical Support and Maintenance Employees

    1,017,863

    Cdn$

    2,864,355

    (g)

    The types of costs that were incurred and capitalized in 2004 were:-

    Rent

    Cdn$

    10,857

    Amortization

    11,977

    Insurance

    885

    Interest

    1,903

    Payroll *

    *571,600

    Professional and Consulting fees

    62,757

    Cdn$

    659,979

Las Vegas From Home.com Entertainment Inc.

6th Floor, 1199 West Hastings Street,

Vancouver, B.C. Canada V6E 3T5

Tel: (604) 681-0204 Fax: (604) 681-9428

Website: www.lvfh.com email: info@lvfh.com

Ms. Linda Cvrkel

Branch Chief

United States Securities & Exchange Commission

August 4th, 2005

Page 3

    *

    (1)

    Does not include any of the Stock Based Compensation Expense which is stated in 1(f)(i)
above

    (2)

    Does not include any of the Salaries for Administration which is stated in 1(f)(ii) above

    (3)

    Does not include any of the Salaries for Customer Service Employees which is stated in
1(f)(iii) above

    (4)

    Capitalized portion of Programming Payroll is directed at technically feasible
programming enhancements as described in 1(c) above

Finally, we confirm to you that the Company does not include in capitalized software the costs of
computer maintenance, customer support and programming payroll not specifically directed at
technically feasible programming enhancements. Furthermore, we confirm that such costs have not
been included in capitalized software on the Company’s financial statements.

In closing this letter we confirm that:-

    •

    the Company is responsible for the adequacy and accuracy of the disclosures in the
filings; and

    •

    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.

Yours sincerely,

LAS VEGAS FROM HOME.COM ENTERTAINMENT INC.

“Bedo H. Kalpakian”

Bedo H. Kalpakian

Chairman and CFO

BK/pk

Cc: Smythe Ratcliffe, Chartered Accountants

Las Vegas From Home.com Entertainment Inc.

6th Floor, 1199 West Hastings Street,

Vancouver, B.C. Canada V6E 3T5

Tel: (604) 681-0204 Fax: (604) 681-9428

Website: www.lvfh.com email: info@lvfh.com