SecProbe.io

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										August 11, 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 your August 10, 2005 response letter 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 comments
are
inapplicable or a revision is unnecessary.  We also ask you to
provide
us with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary in your
explanation.
We look forward to working with you in these respects and welcome
any
questions you may have about any aspects of our review.

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

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

Liquidity and Capital Resources, page 19

1. We note from your response to comment 4 that you have reflected
the
accounting for the shares of restricted stock in the Form SB-2,
however the disclosure appears only to be made in the notes to the
financial statements.  Please revise your filing to include the
disclosure of the accounting for the shares of restricted stock in
the
MD&A section of the Form SB-2.

Financial Statements for the interim period ended March 31, 2005
included in Form SB-2 and Form 10-QSB for the quarter ended March
31,
2005

Note 7. Subsequent Event

2. Tell us and explain in Note 7 how the conversion terms of the
$75,000 convertible note payable to Advantage Fund One LLC that
was
converted into 25,000,000 shares (at a conversion price of $.003)
was
determined. Please indicate in your response and in your revised
disclosure whether this note provided for a beneficial conversion
feature. If so, please disclose how it was accounted for in your
financial statements. If not, please explain why.

Note 8. Issuance of Restricted Stock

3. The disclosures in Note 8 which indicate that the 1,478,940
shares
issued to Cornell Capital Partners were valued at $.03 or $44,368
are
inconsistent with the disclosures provided in Item 2 of your Form
10-
QSB which indicate the shares were valued at $.02 or $29,578.
Also,
the disclosure in Note 8 indicating that the 500,000 shares issued
to
Newbridge Securities were valued at $.03 or $15,000 are
inconsistent
with the disclosures in Item 2 which indicate the shares were
valued
at $.02 or $10,000. Please reconcile and revise these disclosures.

Note 13. Convertible Debt,

4. We note that you have revised the Form SB-2 to include a note
disclosing information related to the conversion of notes payable
into
restricted stock, however we do not believe that the disclosure
clearly reflects the transactions.  Please revise your disclosure
to
clearly present the entire transaction, beginning with the date
that
it occurred, the parties involved and the transaction that took
place.
Additionally, please tell us and include in your disclosure how
you
determined the value of the stock to be issued for the conversion
of
the $39,500 note payable.

5. Also, the disclosures in Note 13 are inconsistent with the
disclosures provided in Item 2 of your Form 10-QSB. For example,
Item
2 indicates that 500,000 shares valued at $.02 or $10,000 were
issued
for a note conversion whereas Note 13 indicates that 500,000
shares
were converted at $.01 in accordance with the original agreement
for a
note conversion of $5,000. Similarly, Item 2 indicates that
3,650,000
shares valued at $.02 or $73,000 were issued for a note conversion
whereas note 13 indicates 3,600,000 shares was issued to convert a
note for $39,500. Please reconcile and revise these disclosures.

Financial Statements for the year ended December 31, 2004
Note 13.  Acquisition of Coreflix, page F-25

6. We note from your response to comment 5 that you have added a
note
to the financial statements as of December 31, 2004 to describe
the
Coreflix transaction, however the note does not appear to be
appropriately descriptive of the transaction or include the
disclosures required in paragraphs 51-55 of SFAS 141.  Please
revise
your note to include details of the transaction such as the date
of
the acquisition, the purchase price, the percentage of voting
interest
acquired, the amount assigned to each major asset and liability of
Coreflix, etc.  See paragraphs 51-55 of SFAS No. 141. Your current
disclosures appear to imply that management does not believe this
acquisition transaction is material. However, we do not concur
with
this conclusion as the total consideration issued in this
transaction
was $120,000 or more than 10% of the Company`s total assets.
Accordingly, please revise to include the requested disclosures.
In
addition, please revise your statement of changes in shareholders`
equity to provide separate disclosure of the shares issued in this
acquisition transaction as it is currently unclear where this
transaction has been reflected in your statement of changes in
shareholders` equity.

Other

7. 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 via EDGAR 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.

You may contact Claire Erlanger 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
Americana Publishing, Inc
August 11, 2005
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