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Unassociated Document

EPOD
International Inc.

2223
Hayman Road

Kelowna,
BC V1Z 1Z6

May 5,
2005

VIA
FACSIMILE (202) 942-9528 and OVERNIGHT MAIL

Mr. H.
Roger Schwall

Assistant
Director

Division
of Corporate Finance

Securities
and Exchange Commission

Washington,
D.C. 20549 - 0405

      Re:

      EPOD
      International Inc.

      Form
      10-KSB for the year ended December 31, 2004, filed March 15,
      2005,

    File No. 0-32327;

Dear Mr.
Schwall:

On behalf
of EPOD International Inc. (the "Company"), we submit the following responses to
comments set forth in your letter to us dated April 21, 2005 in connection with
the above-referenced filings. For purposes of simplicity, each enumerated
paragraph below corresponds to the comment set forth in your
letter.

Company’s
Response to Comment 1:

The
column headings within the financial statements will be revised to reflect:
“From July 11, 2003 (Inception) to December 31, 2003” for the consolidated
statements of operations and cash flows. This will be revised in the amended
filing.

Company’s
Response to Comment 2:

The
Company originally believed that because there was a reverse merger with
Cyokonos, that the predecessor auditor opinion would not be needed, however, the
predecessor auditor’s opinion dated May 28, 2004 will be included in the amended
filing.

Company’s
Response to Comment 3:

The
consolidated notes to the financial statements (Notes 1 and 4) will be revised
to reflect the reconciliation of the Statement of Stockholders’
Equity.

As
described in Notes 1 and 4, the Company’s reorganization involved the exchange
of 9,230,000 shares, which was effectively reduced by 3,950,000 shares of
returned stock. The net resulting shares of 5,280,000 became 10,560,000 after
the Company’s September 2004 stock split. The share figure of 10,560,000
effectively represents the continuing shares attributable to the shareholders of
Cyokonos, which was the registrant prior to the recapitalization.

As
described in the Exchange Agreement between Cyokonos and EPOD, the EPOD
shareholders tendered all 5,000 shares of EPOD common stock to Cyokonos, which
in turn tendered 3,600 shares of restricted common stock of Cyokonos for each
share of EPOD stock received. The net resulting 18,000,000 shares (equivalent to
5,000 x 3,600) became 36,000,000 when adjusted for the aforementioned stock
split.

In the
reorganization, the Company’s continuing operations were that of EPOD
International Inc., while Cyokonos was treated as the registrant without any
continuing operations. Because the operating company effectively acquired more
than 80% of the outstanding shares of the public shell, the transaction was
reported as a reverse merger. Accordingly, the reverse acquisition was treated
as a recapitalization requiring no step-up in the historical info of
EPOD.

Conclusion:

We
sincerely appreciate your prompt review and response to the aforementioned
filing. We hope the above listed responses adequately answered the questions and
concerns raised in your letter. If the above does not adequately address your
concerns, please contact us at your earliest convenience. We are preparing an
amended filing, and will file our 10-KSB/A along with a copy of this letter,
early next week.

If you
have any further questions regarding this letter or any other matter, please
feel free to give me a call at 250-863-9570.

    Yours very truly,

    /s/ L. Mark
Roseborough

    L. Mark Roseborough

    President

    Chief Financial Officer