SecProbe.io

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June 23, 2005

Mr. Nicholas Alexander
Secretary and Director
Exim Internet Group, Inc.
7683 SE 27th Street
Mercer Island, WA  98040

RE:  	Form 8-K Item 4.01 filed June 22, 2005
	File # 0-27825

Dear Mr. Alexander:

We have reviewed your filing and have the following comments.
Where indicated, we think you should revise your documents 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 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
number
listed at the end of this letter.

1. Please revise the "date of report" on the cover of your Form
8-K
to indicate the date of the earliest event upon which you are
reporting.  This appears to be June 20, 2005, the date you ended
the engagement of Cordovano & Honeck, LLP.

2. Please amend the Form 8-K to state whether the former
accountant
resigned, declined to stand for re-election or was dismissed, as
required by Item 304(a)(1)(i) of Regulation S-B.

3. Item 304(a)(1)(ii) of Regulation S-B requires a statement
whether the accountant`s report on the financial statements for
either of the past two years contained an adverse opinion or a
disclaimer of opinion or was qualified or modified as to
uncertainty, audit scope or accounting principles; and a
description of the nature of each such adverse opinion,
disclaimer
of opinion, modification or qualification.  This would include
disclosure of uncertainty regarding the ability to continue as a
going concern in the accountant`s report.  Please revise
accordingly.

4. You currently disclose twice that there were no disagreements
with your former accountant, but neither disclosure meets the
requirements of Item 304(a)(1)(iv) of Regulation S-B.  Please
disclose whether during your two most recent fiscal years and
any
subsequent interim period through June 20, 2005 there were any
disagreements with your former accountant on any matter of
accounting principles or practices, financial statement
disclosure,
or auditing scope or procedure, which disagreement(s), if not
resolved to the satisfaction of your former accountant, would
have
caused it to make reference to the subject matter of the
disagreement(s) in connection with its reports.

5. Regarding your disclosure over reportable events, please
revise
to cover the interim period through June 20, 2005 instead of
September 30, 2004.

6. The letter from your former accountant states they reported
on
the financial statements as of December 31, 2004 and 2003.
However, it does not appear that you have filed a Form 10-KSB
for
the year-ended December 31, 2004.  Please tell us if you will be
filing the Form 10-KSB with the audit report of Cordovano and
Honeck LLP; otherwise, your former accountant should not address
the December 31, 2004 financial statements in their Exhibit 16
letter.

7. 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.

*****

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.

Please file your response via EDGAR in response to these
comments
within 5 business days of the date of this letter.  Please note
that if you require longer than 5 business days to respond, you
should contact the staff immediately to request additional time.
You may wish to provide us with marked copies of each amended
filing to expedite our review.  Direct any questions regarding
the
above to the undersigned at (202) 551-3866.

Sincerely,

Jeffrey Gordon
Staff Accountant
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Nicholas Alexander
Secretary and Director
June 23, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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