SecProbe.io

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Mail Stop 3561

									September 26, 2005

Mr. Anthony C. Dike
Chairman and Chief Executive Officer
Meridian Holdings, Inc.
6201 Bristol Parkway
Culver City, CA 90230

      RE:		   Meridian Holdings, Inc.
            	        	Form 10-KSB for Fiscal Year Ended
      December 31, 2004
      Filed May 16, 2005
		Forms 10-KSB/A for Fiscal Year Ended
      December 31, 2004
	  	Form 10-QSB for Fiscal Quarter Ended
		March 31, 2005
		Forms 10-QSB/A for Fiscal Quarter Ended
		March 31, 2005
		Form 10-QSB for Fiscal Quarter Ended
		June 30, 2005
	File No. 000-30018

Dear Mr. Dike:

	We have reviewed your responses contained in the letters
filed
on EDGAR on August 29 and September 14, 2005 and upon reviewing
those
responses issue the following comments.

	We welcome any questions you may have about our comments or
on
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 for Fiscal Year Ended December 31, 2004

Consolidated Financial Statements

Consolidated Statements of Operations, page F-4
1. We read your response to comment number 1 from our letter dated
June 20, 2005, as reissued in our letter dated July 21, 2005.  We
have also reviewed your amendment to your Form 10-KSB for the
fiscal
year ended December 31, 2004, filed on September 6, 2005.  Please
revise your discussion on page 12 and also your disclosure within
Note 13 of your financial statements to indicate that the amount
and
potential interest from the judgment against Sirius Technologies
of
America has not been reflected in the balance sheet or statement
of
operations.  Additionally, the table in Note 14 summarizing your
restatement refers to dates that appear to be incorrect.  Please
tell
us the relevance of these dates indicated and revise your
disclosure.
The table should summarize the amounts as originally reported and
as
restated, both as of December 31, 2004.  Please refer to APB 20
for
further guidance.

Note 1 - Summary of Significant Accounting Policies

Equity Method, page F-7
2. We read your response to comment number 4 from our letter dated
June 20, 2005 as reissued in our letter dated July 21, 2005.  We
have
also reviewed your amendment to your Form 10-KSB for the fiscal
year
ended December 31, 2004,  filed on September 6, 2005.  We note
that
you have restated your financial statements to include the losses
from your equity investments within your statements of operations;
however, you still have not disclosed the current ownership
percentages of your investments accounted for under the equity
method
or explained how you determined that the fair value of your
investment exceeds the carrying value and that a loss in value of
your investment has not occurred.  Please be detailed in your
response.  Refer to paragraphs 6b, 19h and 20a of APB 18.

Item 8a.  Controls and Procedures, page 13
3. We reviewed your amendment to your Form 10-KSB for the fiscal
year
ended December 31, 2004 filed on September 6, 2005.  We note again
that your certifying officers disclose their conclusions as to the
effectiveness of your disclosure controls and procedures as of
March
31, 2005, instead of December 31, 2004.  We again refer you to
Item
307 of Regulation S-B that requires that your certifying officers
disclose their conclusions regarding the effectiveness of your
disclosure controls and procedures "as of the end of the period
covered by the report."  Please revise your Form 10-KSB
accordingly.
Additionally, please revise your Form 10-QSB for the quarter ended
June 30, 2005 to conclude as to the effectiveness of your
disclosure
controls and procedures as of the end of the period, June 30,
2005,
covered by that report.
4. We read your response to comment numbers 8 and 9 from our
letter
dated June 20, 2005 as reissued in our letter dated July 21, 2005.
We have also reviewed your amendments to your Form 10-KSB for
fiscal
year ended December 31, 2004 filed on September 6, 2005 and Form
10-
QSB for the quarterly period ended March 31, 2005 filed on August
29,
2005.  We note that you continue to state that there were no
"significant" changes in your internal controls.  Item 308(c) of
Regulation S-B requires that you disclose "any change" in your
internal control over financial reporting identified in connection
with the evaluation required by paragraph (d) of Exchange Act
Rules
13a-15 or 15d-15 that has materially affected, or is reasonably
likely to materially affect, your internal control over financial
reporting.  Please revise your disclosure in your Form 10-KSB and
all
subsequent Forms 10-QSB including the quarter ended June 30, 2005.

Exhibit 31
5. We note that the amended Form 10-KSB for fiscal year ended
December 31, 2004 filed September 6, 2005 and the amended Form 10-
QSB
for the quarter ended March 31, 2005 filed on August 29, 2005 did
not
include a certification of your principal financial officer.  If
you
no longer have a CFO and the same individual is performing both
duties as your principal executive officer and principal financial
officer then both titles must be listed on the certification,
otherwise please file a separate certification for your principal
financial officer.  Furthermore, please also amend your Form 10-
QSB
for the quarter ended June 30, 2005 for the same matter. For
further
guidance please refer to paragraph (a) of Exchange Act Rules 13a-
14
and 15d-14 and the Sarbanes-Oxley Act of 2002 -  Frequently Asked
Questions issued November 8, 2002 (as revised November 14, 2002),
particularly questions 12 and 15, available at the Division of
Corporation Finance section of our website, www.sec.gov.

      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.  Please furnish a letter that keys your responses
to
our comments and provides any requested information.  Detailed
response letters greatly facilitate our review.  Please file your
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendments and responses
to
our comments.

	You may contact David DiGiacomo at (202) 551-3319 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3843 with any other
questions.

                  Sincerely,

            George F. Ohsiek, Jr.
    					          Branch Chief

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Mr. Anthony Dike
Meridian Holdings, Inc.
September 26, 2005
Page 1

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