SecProbe.io

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<TYPE>CORRESP
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                                                                  Daniel W. Carr
                                                                  John J. Coates
                                                                 Kevin M. Coates
                                                                    H. Alan Dill
455 Sherman Street, Suite 300                                     Robert A. Dill
Denver, Colorado 80203                                            Thomas M. Dunn
Phone: 303-777-3737                                            John A. Hutchings
Fax: 303-777-3823                                                 Stephen M. Lee
www.dillanddill.com                                            Fay M. Matsukage*
                                                                  Adam P. Stapen
                                                                  Jon Stonbraker
                                                                 Craig A. Stoner
                                                               Felicity Tompkins
                                                               Patrick D. Tooley
                                                        *Also licensed in Nevada

June 9, 2005

H. Roger Schwall
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0405

RE:      PATCH INTERNATIONAL, INC.
         10 KSB FOR THE FISCAL YEAR ENDED MAY 31, 2004
         FILED OCTOBER 18, 2004
         FILE NO. 000-28627

Dear Mr. Schwall:

We are addressing the comments of the Staff in its letter dated May 27, 2005,
pursuant to your request. For your convenience, the comments are set forth
below, together with the Company's responses

10 KSB FOR THE YEAR ENDED MAY 31, 2004

DESCRIPTION OF PROPERTY, PAGE 4

KERROBERT AREA, SASKATCHEWAN, CANADA, PAGE 4

1.       WE NOTE YOUR DISCLOSURE THAT "THE ASSETS COVER APPROXIMATELY 40 ACRES,
         WITH THE POTENTIAL OF UP TO 60 DRILLABLE LOCATIONS." PLEASE EXPLAIN TO
         US AND EXPAND YOUR STATEMENT IN FUTURE FILINGS TO EXPLAIN HOW WELL
         SPACING RULES IN SASKATCHEWAN ALLOW 2/3 ACRES PER LOCATION.

         RESPONSE: This statement should have stated that there was a potential
         of up to 80 drillable locations, as the well spacing rules in
         Saskatchewan allow 1/2 acre per location. As 19 wells had been drilled
         at that time, 61 drillable locations were remaining. This will be
         clarified in future filings.

<PAGE>
H. Roger Schwall
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
June 9, 2005
Page 2

2.       HERE YOU STATE, "AS OF JANUARY 31, 2003, PATCH HAD EARNED THE 12.5%
         INTEREST [AND PAID 15.625% OF THE 8/8THS COST] IN THE INITIAL 10 TEST
         WELLS AND, IN CONNECTION THEREWITH, INCURRED $112,809 AS ITS SHARE OF
         THE COSTS ASSOCIATED WITH THE TEST WELLS." THIS IMPLIES THAT THE 8/8THS
         COST FOR THE INITIAL 10 TEST WELLS IS $721,978 [=112,809/.15625]. YOU
         CONTINUE, "FAIRCHILD HAS ALSO CONTRIBUTED ITS 5.208% SHARE OF THE COSTS
         ASSOCIATED WITH THE INITIAL 10 TEST WELLS, BEING $68,772 AND AS A
         RESULT HAS EARNED A 4.167% INTEREST IN THESE WELLS. AS A RESULT,
         PATCH'S NET INTEREST IN THE INITIAL 10 TEST WELLS IS 8.333%." THE
         8/8THS COST IMPLIED HERE IS $1,320,507 [=68,772/.05208]. AMEND YOUR
         FUTURE DOCUMENTS TO ELIMINATE THIS INCONSISTENCY IN 8/8THS WELL COSTS.

         RESPONSE:  Your comment has been noted and the Company's future
         documents will eliminate this inconsistency.

DRILLING ACTIVITY, PAGE 7

3.       YOU INDICATE THAT YOU HAVE DRILLED 23 "COMMERCIALLY VIABLE" WELLS IN
         2003 AND 2004, BUT YOUR TABLE OF PRODUCTIVE WELLS HAS ONLY 19 GROSS
         PRODUCING WELLS. PLEASE AMEND FUTURE DOCUMENTS TO ELIMINATE OR TO
         EXPLAIN THIS INCONSISTENCY.

         RESPONSE:  Your comment has been noted and the Company's future
         documents will eliminate this inconsistency.

MARKET FOR COMMON EQUITY AND RELATED STOCKHOLDER MATTERS, PAGE 8

4.       WE NOTE YOUR DISCLOSURE STATING THAT YOU ISSUED 639,059 SHARES OF
         COMMON STOCK TO A COMPANY EXECUTIVE AS PAYMENT FOR ACCRUED BUT UNPAID
         SALARY OF $30,000. GIVEN THE QUOTED MARKET PRICE OF YOUR SHARES ON THE
         DATE OF ISSUANCE, IT APPEARS THE STOCK CONVEYED HAD A VALUE
         SIGNIFICANTLY IN EXCESS OF YOUR LIABILITY. TELL US HOW YOU DETERMINED
         THE NUMBER OF SHARES THAT WERE ISSUED AND DESCRIBE THE ACCOUNTING
         EFFECTS OF RECORDING THIS TRANSACTION IN YOUR FINANCIAL STATEMENTS.

         RESPONSE: The company executive's agreement stated that the Company
         could satisfy its obligations in respect of payment of the salary in
         any month by the issuance of such number of common shares in the
         capital stock of the Company having a deemed price equal to the average
         bid price of the Company's common stock on the OTC Bulletin Board for
         the last five (5) trading days of such month as having a value equal to
         the salary then otherwise payable.

<PAGE>
H. Roger Schwall
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
June 9, 2005
Page 3

         The Company accounted for the issuance of shares based upon the fair
         value of the stock issued. Since the number of shares issued was based
         upon the average bid price, the value of the stock issued equaled the
         monthly management fee amount.

MANAGEMENT'S DISCUSSION AND ANALYSIS OR PLAN OF OPERATION, PAGE 9

RESULTS OF OPERATIONS, PAGE 9

5.       YOU STATE THAT YOU HAVE MADE EQUITY COMPENSATION TO CONSULTANTS IN LIEU
         OF CASH. IF YOU MADE SUCH COMPENSATION AS PAYMENT FOR YOUR YEAR-END
         PROVED RESERVE ESTIMATES, EXPLAIN TO US HOW YOU WERE SATISFIED THAT THE
         CONSULTANT AVOIDED ANY CONFLICT OF INTEREST.

         RESPONSE:   The Company did not pay for its year-end proved reserve
         estimates with equity compensation.

6.       YOU EXPLAIN THAT THE INCREASE IN REVENUE FOR 2004 WAS PRIMARILY DUE TO
         INCREASED PRODUCTION FROM YOUR CANADIAN PROPERTIES. HOWEVER, IN YOUR
         SCHEDULE ON PAGE F-15, YOU SHOW THAT TOTAL PRODUCTION FOR THE YEAR
         ENDED MAY 31, 2004 DECLINED SIGNIFICANTLY WHEN COMPARED TO PRODUCTION
         IN 2003. PLEASE RECONCILE THESE DISCLOSURES FOR US.

         RESPONSE: The schedule on page F-15 was incorrect as to the production
         amount in the United States for 2003. It should have been 289,837 mcf,
         leaving a balance at the end of the year of 790,345 mcf of gas. Also
         the schedule should have indicated that the reserves in Canada were
         oil. Accordingly, 2004 production in Canada increased by 28,055 bbls of
         oil, while 2004 production in United States decreased by 136,255 mcf of
         gas, thus resulting in the increased revenue in 2004. The Company
         proposes to file an amendment to its 2004 10-KSB which will include
         revised financial statements reflecting this.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS, PAGE F-6

NOTE 3 - ACQUISITION OF SUBSIDIARY, PAGE F-7

7.       IN THE FIRST PARAGRAPH ON PAGE F-6, YOU REFER TO PATCH INTERNATIONAL
         INC. (F.K.A. PRAXIS PHARMACEUTICALS) PRIOR TO THE ACQUISITION OF PATCH
         ENERGY INC. AS A "NON-OPERATING SHELL CORPORATION WITH NOMINAL NET
         ASSETS."  HOWEVER, THE ASSETS AND NET ASSETS CONTRIBUTED BY PRAXIS
         PHARMACEUTICALS, WHICH YOU LIST ON PAGE F-8, APPEAR TO ACCOUNT FOR 86%
         OF THE TOTAL ASSETS, AND VIRTUALLY ALL OF THE STOCKHOLDERS EQUITY OF
         THE COMBINED ENTITIES AS OF MAY 31, 2004.  ADDITIONALLY, YOU DISCLOSE
         THAT THE FORMER PRAXIS PHARMACEUTICALS SHAREHOLDERS RECEIVED 53% OF THE
         TOTAL ISSUED AND OUTSTANDING COMMON SHARES OF THE

<PAGE>
H. Roger Schwall
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
June 9, 2005
Page 4

         COMBINED COMPANY.  TAKING INTO CONSIDERATION THE ABOVE FACTORS, PLEASE
         EXPLAIN TO US THE REASONS YOU DECIDED TO ACCOUNT FOR THE TRANSACTION AS
         A REVERSE TAKEOVER, WITH PRAXIS PHARMACEUTICALS AS THE TARGET ENTITY.
         PLEASE ADDRESS ITEMS (A) THROUGH (E) OF SFAS 141 PARAGRAPH 17 IN THEIR
         ENTIRETY WHEN FORMULATING YOUR RESPONSE.

         RESPONSE: We propose to delete the sentence in Note 1(a) to the
         financial statements referring to the Company being a non-operating
         shell with nominal net assets.

         We have treated Patch Energy Inc. as the acquirer of Praxis
         Pharmaceuticals Inc. in accordance with FASB 141, Paragraph 17(a) to
         (e):

         a)   The relative voting rights in the combined entity after the
              combination - all else being equal, the acquiring entity is the
              combining entity whose owners as a group retained or received the
              larger portion of the voting rights in the combined entity. In
              determining which group of owners retained or received the larger
              portion of the voting rights, consideration shall be given to the
              existence of any unusual or special voting arrangements and
              options, warrants or convertible securities.

              The major shareholder of Patch Energy Inc. controlled 47% of the
              shares of the combined entity. In itself, this was not enough to
              consider the acquiror to be Patch Energy Inc.

         b)   The existence of a large minority voting interest in the combined
              entity when no other owner or organized group of owners has a
              significant voting interest - all else being equal, the acquiring
              entity is the combining entity whose single owner or organized
              group of owners holds the large minority voting interest in the
              combined entity.

              One shareholder of the combined entity held 47% of the shares of
              that entity. There were no other holders of blocks of shares equal
              to or greater than 5% of the total issued capital. Effectively,
              that one shareholder had control of the combined entity. For this
              reason, Patch Energy Inc. was treated as the acquiror.

         c)   The composition of the governing body of the combined entity - all
              else being equal, the acquiring entity is the combining entity
              whose owners or governing body has the ability to elect or appoint
              a voting majority of the governing body of the combined entity.

              Due to the 47% holding of one shareholder of the combined company,
              along with the lack of other large blocks of shares, this one
              shareholder had the ability to elect the majority of the board of
              directors.

<PAGE>
H. Roger Schwall
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
June 9, 2005
Page 5

         d)   The composition of the senior management of the combined entity -
              all else being equal, the acquiring entity is the combining entity
              whose senior management dominates that of the combined entity.
              Senior management generally consists of the chairman of the board,
              chief executive officer, chief operating officer, chief financial
              officer, and those divisional heads reporting directly to them, or
              the executive committee if one exists.

              Senior management of the combined entity comprised David Stadnyk
              as President, Chief Executive Officer and Director. The other
              Director was Winston Cabell. The only Director of Patch Energy
              Inc. was David Stadnyk. There were no other senior management
              officials. The senior management of Patch Energy Inc. dominated
              the combined entity.

         e)   The terms of the exchange of equity securities - all else being
              equal, the acquiring entity is the combining entity that pays a
              premium over the market value of the equity securities of the
              other combining entity or entities.

              Neither Patch nor Praxis paid a premium for the business
              combination transaction.

NOTE 5 - AVAILABLE-FOR-SALE SECURITIES, PAGE F-8

8.       YOU DISCLOSE THAT YOU HAVE RECOGNIZED A DISCOUNT FROM THE QUOTED MARKET
         VALUE OF SECURITIES HELD FOR SALE DUE TO SEVERAL FACTORS, INCLUDING
         LACK OF MARKETABILITY DUE TO TRADING RESTRICTIONS, ABILITY TO DISPOSE
         OF A LARGE BLOCK OF SHARES, AND THE RISK ASSOCIATED WITH A STARTUP
         COMPANY. PLEASE SUBMIT A SCHEDULE SHOWING THE PER SHARE AND AGGREGATE
         MARKET VALUES OF THE SHARES FOR EACH PERIOD PRESENTED, AS WELL AS THE
         DISCOUNTS ASSOCIATED WITH EACH FACTOR YOU IDENTIFY, RECONCILED TO THE
         AMOUNTS UTILIZED IN YOUR VALUATIONS. TELL US HOW THE DISCOUNTS WERE
         DETERMINED AND DESCRIBE ANY INFORMATION THAT YOU HAVE ABOUT THE
         INVESTEE THAT YOU BELIEVE IS NOT REFLECTED IN THE QUOTED MARKET PRICE
         OF ITS SHARES.

         RESPONSE:  We enclose a Schedule of Investment in Pharmaxis Ltd. as at
         May 31, 2004 illustrating the calculation of the per share and
         aggregate market values of the available for sale securities as at that
         date.

         The discount was determined by taking into account the following
         factors:

         a)   Large block holding of shares with no trading history.
         b)   Shares are restricted from trading until November 2005.

<PAGE>
H. Roger Schwall
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
June 9, 2005
Page 6

         c)   Risk that investee, a research and development start-up company,
              will not sustain sufficient market interest or effective
              operations until the shares can be sold.

         We initially discounted the market price by 60% of trading price at
         November 2003, the month in which the investee's stock was listed on
         the Australian Stock Exchange. We attributed a 20% discount to each of
         the factors in (a), (b) and (c). The discount is being decreased at a
         rate of 2.5% per month. By November 2005, the date the shares become
         unrestricted, the shares will be valued at 100% of the market price,
         net of anticipated taxes payable.

         The discount amounts, individually and in the aggregate, represent
         management's best estimate of the ultimate realization of its
         investment at the time the financial statements were prepared, taking
         into account management's expectation of when realization will occur.
         The Company is not represented on the investee's Board of Directors and
         the Company has no information regarding the investee other than
         information publicly available to all investors.

         The discount method is reviewed continually to take into account any
         factors which may impact our methodology. To date, we have consistently
         applied the basis of calculating and applying the discount.

NOTE 8 - COMMON STOCK, PAGE F-12

9.       Tell us why you have not disclosed stock option activity for all
         periods presented, as is generally required under SFAS 123, paragraph
         47.

         Response: The Company proposes to file an amendment to its 2004 10-KSB
         which will include revised financial statements reflecting 2003
         information. This information was inadvertently deleted from the
         previously filed financial statements.

NOTE 13 - SCHEDULE