SecProbe.io

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Room 4561
								November 7, 2005

Mr. Alex Genin
Chief Executive Officer and Director
First Capital International, Inc.
5120 Woodway
Suite 9000
Houston, TX 77056

Re:	First Capital International, Inc.
	Item 4.01 Form 8-K
      Filed November 3, 2005
	File No.  000-26271

Dear Mr. Genin:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with more
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.

Form 8-K filed November 3, 2005

1. We note that Ham, Langston & Brezina, L.L.P. resigned on
October
5, 2005 yet you filed your Form 8-K on November 3, 2005. Please
note
that the filing was due on the fourth day following the date the
relationship with Ham, Langston & Brezina, L.L.P. ceased.

2. Your disclosure indicates that there have been no disagreements
with the former accountants but you do not specify the time period
in
which there were no disagreements.  Please revise your disclosure
to
state whether during the two most recent fiscal years and the
subsequent interim period through the date of the resignation
there
have been any disagreements with the former accountants.

3. Please revise your disclosure regarding consultations with your
new auditor to state whether there were consultations in the two
most
recent fiscal years and the subsequent interim period.  See Item
304(a)(2) of Regulation S-B.

4. To the extent that you make changes to the Form 8-K to comply
with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.

       As appropriate, please respond to these comments within
five
business days or tell us when you will respond.  Please submit all
correspondence and supplemental materials on EDGAR as required by
Rule 101 of Regulation S-T.  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 amendment and 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 Christine Davis, Staff Accountant, at (202)
551-
3408, Robert Benton, Review Accountant at (202) 551-3804 or me at
(202) 551-3489 if you have questions regarding these comments.

							Sincerely,

      Brad Skinner
							Accounting Branch Chief
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Mr. Alex Genin
First Capital International, Inc.
November 7, 2005
Page 3

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