SecProbe.io

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United States
Securities and Exchange Commission
100 F Street, N.W.
Washington, DC 20549
Attn Scott Ruggiero, Staff Accountant
Division of Corporation Finance

            Re:   Response to comments on Pickups Plus, Inc. form 10-KSB for the
                  fiscal year ended December 31, 2004.

Dear Mr. Ruggiero,

Please find below our responses to your comments regarding the above referenced
form 10-KSB in your letter dated August 18, 2005. Your comment numbers lists
each of the responses.

Exhibits, Page 22

1.    We will file Exhibit 21 listing our subsidiaries in accordance with item
      601 (b)(21) of Regulation S-B.

2.    We will file, as Exhibit 23, the consent from our independent accountants
      to incorporate by reference our financial statements into our previously
      filed registration statements in accordance with item 601(b)(23)(ii) of
      Regulation S-B.

Statement of Cash Flows, page F-6

3.    We concur that the 2004 Consolidated Statement of Cash Flows should be
      revised to remove $175,000 from the Compensatory shares in the cash flows
      from operating activities section and reflected in the Net Proceeds from
      Credit line and demand loan line item. This will be reflected in an
      amended 2004 Consolidated Statement of Cash Flows.

4.    The 2004 Statement of Cash Flows has been revised to correctly present all
      line items net of assets acquired with the purchase of Auto Preservation.
      $25,500 of the fixed assets acquired was reported incorrectly on the
      Statement of Cash Flows. Please note that no liabilities were assumed in
      this transaction.

Notes to Financial Statements, page F-7
Notes 3 - Summary of Significant Accounting Policies, page F-9
(h) Earnings (loss) Per Share

5.    In preparing our response to this comment we verified that there were no
      common stock warrants issued or outstanding. In our amended filing we will
      change the language in the footnote to remove the reference to the
      warrants.

<PAGE>

Note 4 - Acquisition, page F-12

6.    The Company's primary reason for completing the acquisition of AP was to
      leverage the goodwill that was generated over the 15 years of operating
      the business and to expand it on a national basis. The Company is
      utilizing the AP operating, sales, training and marketing plans to enhance
      its existing national Franchise and distribution offerings. Therefore we
      do believe that the acquisition price is goodwill except for actual fair
      market value of the physical assets we received.

      The customer lists and customer relationships, were all related to the AP
      business that operated within Cincinnati OH only. That business operated
      on a very small operating profit basis and had no customer contracts. The
      fixed assets portion of the acquisition was allocated to the Cincinnati
      part of the business. Therefore, the Company put no additional value to
      the existing customer lists or relationships. As for the royalty-free
      license, our due diligence of other distribution agreements that AI had
      and continues to have in place shows that every distributor they secured
      for a country got the license to use the ValuGard name at no charge. For
      that reason we put no value on the license itself.

Note 11 - Income Taxes, page F-15

7.    The Footnote will be changed as follows:

<TABLE>
<CAPTION>
                                                                                 2004                 2003
                                                                         --------------------- -------------------

     Deferred tax assets and liabilities:
<S>                                                                                 <C>                 <C>
     Net operating loss carry forwards                                              2,100,000           1,650,000
     Provision for doubtful accounts                                                   12,908               2,372
     Amortization of Goodwill                                                          11,751                   0
                                                                         --------------------- -------------------
                                                                                    2,124,659           1,652,372

     Less: Valuation allowance                                                    (2,124,659)         (1,652,372)

     Net deferred income tax asset                                                      0                  0
                                                                         ===================== ===================

 For the years ended December 31, 2004 and 2003 the income tax benefit
 difference from the amount computed by applying a federal tax rate of
 34% is as follows:

                                                                                 2004                 2003
                                                                         --------------------- -------------------

     Benefit at federal Statutory rate                                             $(401,444)          $(298,712)
     State income taxes, net of federal                                              (70,843)            (52,714)
     Change in valuation allowance                                                    472,287             351,426
                                                                         --------------------- -------------------

     Income Tax Benefit                                                                $0                 $0
                                                                         ===================== ===================
</TABLE>

<PAGE>

Note 12 - Commitments and Contingencies, page F-15
(a) Lease Obligations, page F-15

8.    The After reviewing your comment, we concur with your comment and will
      change Note 12 to reflect the following future minimum lease payments:

      On October 6, 2004 the Company entered into a lease for a commercial
      building that calls for a rent payment of $2,950 per month and $316.06 for
      real estate taxes monthly. The lease expires October 30, 2006.

      There is also a remaining balance due under capital leases of $22,804 all
of which is currently due.

      The Future minimum lease payments are as follows:

      2005        $61,996
      2006         32,660
                 --------
      Total       $99,656

      Exhibits 32.1 and 32.2

9.    Please find attached the revised certifications that we have integrated
      into our amended filings.

We acknowledge 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.

------------------
Merritt Jesson
Chief Executive Officer

------------------
Robert White
Chief Financial Officer

<PAGE>

                                   Exhibit 21
                              List of Subsidiaries

Auto Preservation, Inc. (an Ohio Corporation)        100% owned

<PAGE>

            Consent of Independent Registered Public Accounting Firm

Board of Directors
Pickups Plus, Inc.

We consent to the incorporation by reference of our Report of Independent
Registered Public Accounting Firm dated March 25, 2005 on the consolidated
balance sheet as of December 31, 2004 and the related consolidated statements of
operations, stockholders' equity (deficit) and cash flows for the years ended
December 31, 2004 and 2003 included in this Form 10-KSB/A, into the Company's
previously filed Registration Statements.

Lazar Levine & Felix LLP
Certified Public Accounts

New York, New York
September 21, 2005

<PAGE>

                                  Exhibit 31.1

                            CERTIFICATION PURSUANT TO
                  SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Merritt Jesson, certify that:

           1. I have reviewed this form 10-KSB/A for the year ended December 31,
           2004 of Pick-Ups Plus, Inc.;

           2. Based on my knowledge, this report does not contain any untrue
           statement of a material fact or omit to state a material fact
           necessary to make the statements made, in light of the circumstances
           under which such statements were made, not misleading with respect to
           the period covered by this report;

           3. Based on my knowledge, the financial statements, and other
           financial information included in this report, fairly present in all
           material respects the financial condition, results of operations and
           cash flows of the small business issuer as of, and for, the periods
           presented in this report;

           4. The small business issuer's other certifying officer(s) and I are
           responsible for establishing and maintaining disclosure controls and
           procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e))
           for the small business issuer and have:

                            (a) Designed such disclosure controls and
           procedures, or caused such disclosure controls and procedures to be
           designed under our supervision, to ensure that material information
           relating to the small business issuer, including its consolidated
           subsidiaries, is made known to us by others within those entities,
           particularly during the period in which this report is being
           prepared;

                            (b) Omitted;

                            (c) Evaluated the effectiveness of the small
           business issuer's disclosure controls and procedures and presented in
           this report our conclusions about the effectiveness of the disclosure
           controls and procedures, as of the end of the period covered by this
           report based on such evaluation; and

                            (d) Disclosed in this report any change in the small
           business issuer's internal control over financial reporting that
           occurred during the small business issuer's most recent fiscal
           quarter (the small business issuer's fourth fiscal quarter in the
           case of an annual report) that has materially affected, or is
           reasonably likely to materially affect, the small business issuer's
           internal control over financial reporting; and

           5. The small business issuer's other certifying officer(s) and I have
           disclosed, based on my most recent evaluation of internal control
           over financial reporting, to the small business issuer's auditors and
           the audit committee of the small business issuer's board of directors
           (or persons performing the equivalent functions):

                            (a) All significant deficiencies and material
           weaknesses in the design or operation of internal control over
           financial reporting which are reasonably likely to adversely affect
           the small business issuer's ability to record, process, summarize and
           report financial information; and

                            (b) Any fraud, whether or not material, that
           involves management or other employees who have a significant role in
           the small business issuer's internal control over financial
           reporting.

Date:    September 21, 2005             By:_______________________________
                                           Name:    Merritt Jesson
                                           Title:   Chief Executive Officer

*The introductory portion of paragraph 4 of the Section 302 certification that
refers to the certifying officers' responsibility for establishing and
maintaining internal control over financial reporting for the company, as well
as paragraph 4(b), have been omitted in accordance with Release No. 33-8545
(March 2, 2005) because the compliance period has been extended for small
business issuers until the first fiscal year ending on or after July 15, 2006.

<PAGE>

                                  Exhibit 31.2

                            CERTIFICATION PURSUANT TO
                  SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Robert White, certify that:

           1. I have reviewed this form 10-KSB/A for the year ended December 31,
           2004 of Pick-Ups Plus, Inc.;

           2. Based on my knowledge, this report does not contain any untrue
           statement of a material fact or omit to state a material fact
           necessary to make the statements made, in light of the circumstances
           under which such statements were made, not misleading with respect to
           the period covered by this report;

           3. Based on my knowledge, the financial statements, and other
           financial information included in this report, fairly present in all
           material respects the financial condition, results of operations and
           cash flows of the small business issuer as of, and for, the periods
           presented in this report;

           4. The small business issuer's other certifying officer(s) and I are
           responsible for establishing and maintaining disclosure controls and
           procedures (as defined in Exchange Act Rules 13a-15(e) and 15d-15(e))
           for the small business issuer and have:

                            (a) Designed such disclosure controls and
           procedures, or caused such disclosure controls and procedures to be
           designed under our supervision, to ensure that material information
           relating to the small business issuer, including its consolidated
           subsidiaries, is made known to us by others within those entities,
           particularly during the period in which this report is being
           prepared;

                            (b) Omitted;

                            (c) Evaluated the effectiveness of the small
           business issuer's disclosure controls and procedures and presented in
           this report our conclusions about the effectiveness of the disclosure
           controls and procedures, as of the end of the period covered by this
           report based on such evaluation; and

                            (d) Disclosed in this report any change in the small
           business issuer's internal control over financial reporting that
           occurred during the small business issuer's most recent fiscal
           quarter (the small business issuer's fourth fiscal quarter in the
           case of an annual report) that has materially affected, or is
           reasonably likely to materially affect, the small business issuer's
           internal control over financial reporting; and

           5. The small business issuer's other certifying officer(s) and I have
           disclosed, based on my most recent evaluation of internal control
           over financial reporting, to the small business issuer's auditors and
           the audit committee of the small business issuer's board of directors
           (or persons performing the equivalent functions):

                            (a) All significant deficiencies and material
           weaknesses in the design or operation of internal control over
           financial reporting which are reasonably likely to adversely affect
           the small business issuer's ability to record, process, summarize and
           report financial information; and