SecProbe.io

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							April 21, 2005

via facsimile and U.S. mail

Mr. L. Mark Roseborough
Chief Financial Officer
EPOD International, Inc.
2223 Hayman Road
Kelowna, British Columbia
Canada  V1Z 1Z6

	Re:	EPOD International, Inc.
		10-KSB for the year ended December 31, 2004
		File No. 0-32327

Dear Mr. Roseborough:

      We have reviewed the above filing and have the following
accounting comments.  Our review has been limited to your
financial
statements and the related disclosures in Management`s Discussion
and
Analysis.  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 comments are inapplicable or
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 supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

10-KSB for the year ended December 31, 2004

Financial Statements, page 15

General

1. As it appears you have reflected no activity in your financial
statements prior to July 11, 2003, the date of inception, please
re-
label all column headers in the filing currently labeled "Year
Ended
December 31, 2003," as appears on pages 18 and 20, with "From July
11, 2003 (Inception) to Dec. 31, 2003," or similar language, to
clarify that the activity reported does not relate to the full
year.

Audit Report

2. We note that your auditors have attributed audit responsibility
for the December 31, 2003 financial information to other auditors.
If you are able to secure permission from the other auditor to
include its report in your filing, please amend your filing to
include the audit report of the other auditor.  Otherwise, it will
be
necessary to amend your filing to re-label all financial
information
not covered by the more recent audit as unaudited, and to update
the
more recent audit opinion;  under these circumstances, your
current
auditor should remove from its report any reference to other
auditors.  Further, if you have appropriately described your
reorganization as a recapitalization on page 21, the language in
the
audit opinion casting the December 31, 2003 financial information
as
that of a predecessor entity would be imprecise and should
therefore
be removed.

Note 1 - Organization and Description of Business, page 21

3. Please reconcile the statements, referring to your
reorganization
with Cyokonos Corporation, "the Company issued 18,000,000 shares
of
its restricted common stock for all of the issued and outstanding
common shares of Cyokonos," and "[t]his reorganization was
accounted
for as though it were a recapitalization of the Company and sale
by
the Company of 9,230,000 shares of common stock...."  Also
reconcile
these amounts to the 10,560,000 figure reflected on page 19 as
"reverse acquisition and recapitalization," and the 18,460,000
amount
mentioned on page 26.  Tell us why you have characterized the
transaction as a reverse acquisition in your Statement of
Stockholders` Deficit.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
your amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the 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 Karl Hiller at (202) 942-1981 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 942-1870 with any other
questions.  Direct all correspondence to the following ZIP code:
20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

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EPOD International Inc.
April 21, 2005
page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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