SecProbe.io

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						July 12, 2005

Mail Stop 3561

Via US Mail and Facsimile

Mr. George Lovato, Jr.
President and Chief Executive Officer
303 San Mateo NE, Suite 104A
Albuquerque, New Mexico 87108

Re:	Americana Publishing, Inc.
      Form SB-2 Filed May 9, 2005
      Form 10-KSB for the year ended December 31, 2004
	Commission file #: 000-25783

Dear Mr. Lovato:

We have reviewed the above referenced filing and have the
following
comments.  Please file an amended Form 10-KSB and Form SB-2 in
response to our request for expanded or revised disclosure.  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 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 any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

* * * * * * * * * * * * * * * * * * * * * * *

Form SB-2 filed May 9, 2005
Form 10-KSB for the year ended December 31, 2004

General

1. Please ensure that you have incorporated our previous comments
into your financial statements and disclosures included in your
Form
SB-2 filed May 9, 2005 and into your Annual Report on Form 10-KSB
for
the year ended December 31, 2004 and subsequent Quarterly Reports
on
Form 10-QSB.  This would include our comments relating to
convertible
debt, obligations in default, going concern, and subsequent
events,
among others.  In this regard, please address the following:

Your disclosures in Note 6 indicate that all convertible debt was
converted to common stock during 2004 but your balance sheet lists
$114,000 of convertible debt outstanding to related parties and
$257,300 of "June Convertible Debt. Revise to disclose the terms
of
the convertible debt outstanding at December 31, 2004 as reflected
in
your balance sheet and explain how the conversion terms were
determined. Also, please indicate whether the debt provided for a
beneficial conversion feature, and if so explain how the
accounting
treatment used complied with EITF 98-5 and EITF 00-27.
Furthermore,
the debt converted as disclosed in Note 6 of $387,500 does not
agree
to the debt converted to equity as reflected in your statement of
shareholders` deficit of $332,916. Please reconcile and revise
these
disclosures. Also, revise Note 6 to indicate that the beneficial
conversion feature was recognized in 2001 not 2004.

Tell us and clarify in your financial statements whether the
convertible notes that were converted into common shares during
2004
and 2005 were converted in accordance with their original terms or
pursuant to induced conversions which should be accounted for in
accordance with SFAS No.84. If the conversions not made in
accordance
with the original terms, please explain how the revised conversion
prices were determined, explain how they compared to the fair
value
of your shares at the date the revised conversion terms were
agreed
to and explain why you believe your accounting treatment for the
conversions was appropriate.

The events disclosed in Note 11 do not appear to be "subsequent
events" and should be included in audited notes to your financial
statements. Please revise.

Independent Auditor`s Report

2. We note that the independent auditor`s report included in the
Form
10-KSB for the year ended December 31, 2004 and the Form SB-2
filed
on May 9, 2005 covers only the year ended December 31, 2004.
Because
your financial statements include both 2003 and 2004, you must
include an auditors report that also covers the year ended
December
31, 2003.  Please revise both filings to include audit reports
covering both 2003 and 2004.

Notes to Financial Statements

Note 4.  Property Plant & Equipment

3. We note that a significant amount of your property and
equipment
consists of audio production costs.  Please revise your disclosure
to
explain the nature of these costs as well as the method of
amortization.  Also tell us how you ensure that the asset balance
is
realizable and is not impaired.  Additionally, in light of the
significance of property and equipment to your total assets please
tell us and include a disclosure as to how and when you analyze
these
assets for impairment.  Consider the requirements in SFAS 144.

Registration Statement on Form SB-2
Liquidity and Capital Resources

4. Disclose how you will value and account for the warrants to
acquire 375,000 shares of common stock at a price of $.001 per
common
share that were issued to Montgomery Equity Partners Ltd. in
connection with their issuance of a note for $820,000. If no value
was assigned to the warrants, please explain why.

5. Disclose in the notes to your financial statements and MD&A how
you valued and accounted for the shares of restricted common stock
that were issued to Newbridge Securities and Cornell Capital
Partners
during the first quarter of 2005.

Coreflix, page 24

6. Revise your financial statements to include all of the
disclosures
required by SFAS No.141 with respect to the acquisition of
Coreflix
or explain in detail why you do not believe these disclosures are
required. Also, explain in the notes how you valued the shares
issued
in connection with this transaction.

Warrants, page 35

7. Disclose in your financial statements the nature and terms of
the
transaction in which the Company issued warrants to acquire
13,896,060 shares of common stock at an exercise price of $.001
per
share on April 1, 2005. As part of your revised disclose, explain
how
the warrants were valued and accounted for in your financial
statements.

Other

8. Provide a currently dated consent of the independent accountant
in
any future amendments to your Form SB-2 registration statement.

9. Please update the financial statements and related disclosures
included in your Form SB-2 registration statement in accordance
with
Item 310(g) of Regulation S-B.

* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter that keys your responses to our comments
and
provides any requested supplemental information.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings 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 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 filings;

* 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 Claire Lamoureux at 202-551-3301 or me at 202-551-
3813 if you have questions.

								Sincerely,

								Linda Cvrkel
								Branch Chief
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Mr. George Lovato, Jr.
Americana Publishing, Inc.
July 12, 2005
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