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      Unassociated Document

      AMERICANA
        PUBLISHING, INC.

      303
        San Mateo NE, Suite 104A

      Albuquerque,
        New Mexico 87108

      September
        22, 2005

      Ms.
        Linda
        Cvrkel

      Securities
        and Exchange Commission

      450
        5th
        Street
        NW

      Washington,
        DC 20549

              Re:
              Americana Publishing, Inc.

              Form SB-2 Filed May 9, 2005

              Form 10-KSB for the year ended December
                31,
                2004

              Form 10-QSB for the periods ended
                March 31,
                2005 and June 30, 2005

              Commission file #:
                000-25783

      Dear
        Ms.
        Cvrkel,

      This
        letter is in response to your letter dated September 19, 2005, received in
        our
        office the same day by facsimile, commenting on the following documents:
        SB-2
        filed May 9, 2005, Form 10-KSB for the year ended December 31, 2004 and Forms
        10-QSB for the periods ended March 31, 2005 and June 30, 2005.

      Form
        SB-2 filed May 9, 2005- Management’s Discussion and
        Analysis

            1.

              General,
                page 19-We note from your response to prior comment 2 that you made
                the
                requested change to Note 8 in the Form 10-QSB for the period ended
                March
                31, 2005, however, it does not appear that the requested changes
                have been
                made to the MD&A section in the Form SB-2 or to Note 8 to the
                financial statements for the six months ended June 30, 2005 included
                in
                the Form SB-2. As such, we reissue our previous comment and request
                that
                you revise the MD&A section in the Form SB-2 and Note 8 to the
                financial statements for the six months ended June 30, 2005 included
                in
                the Form SB-2 to disclose the type of expense that was recognized
                in your
                statement of operations related to the issuance of restricted stock
                to
                Cornell Capital and Newbridge
                Securities.

      The
        requested changes have been made to the MD&A section of Form SB-2 and to
        Note 8 of the financial statements of Form SB-2.

      Financial
        Statements for the interim period ended June 30, 2005 included in Form SB-2
        and
        Forms 10-QSB for the quarters ended March 31, 2005 and June 30,
        2005

            2.

              Financial
                Statements- We note from your response to prior comment 4 that you
                have
                restated the financial statements as of June 30, 2005 to include
                a loss on
                debt restructuring from the conversion of the Advantage note. Please
                revise the balance sheet as of June 30, 2005 and statement of cash
                flows
                for the six months ended June 30, 2005 included in the Form SB-2
                to
                present the columns as “restated.” The MD&A Results of Operations
                sections in both the Form SB-2 and the Form 10-QSB for the period
                ended
                June 30, 2005 should be revised to discuss the loss on debt restructuring
                as it affects the changes in financial results between June 30, 2004
                and
                June 30, 2005. Additionally, please revise your MD&A section included
                in Form 10-QSB for the period ended June 30, 2005 to discuss the
                accounting for the Advantage note on page 1 in terms of a correction
                of an
                error in previously issued financial
                statements.

      “Restated”
        has been added to the June 30, 2005 balance sheet and the statement of cash
        flows of Form SB-2, as requested. The results of operations has been revised
        to
        discuss the debt restructuring expense in both the June 30, 2005 Form 10-QSB
        and
        Form SB-2. The accounting for the Advantage Note has been added to the June
        30,
        2005 Form 10-QSB and Form SB-2.

      Note
        11. Restatement of Financial Statements

            3.

              Revise
                to disclose the impact of the restatement on your earnings per share
                for
                the three and six months ended June 30, 2005. Refer to the requirements
                of
                paragraph 37 of APB 20.

      The
        earnings per share has been revised as requested.

      MD&A
        Liquidity and Capital Resources

            4.

              We
                note from your response to prior comment 5 that you have revised
                the
                disclosure as requested. However, although we note that Note 10 to
                the
                June 30, 2005 financial statements has been revised to include the
                date
                and amount of all issuances of common stock during the first and
                second
                quarters of 2005 that relate to debt conversion or other non-cash
                transactions, it appears you have not disclosed how the shares were
                valued
                and accounted for in your financial statements. Additionally, it
                does not
                appear that you have added any additional disclosure related to these
                stock issuances to the MD&A section. As such, we reissue our previous
                comment in part and request that you revise the MD&A section of the
                Form SB-2 to include disclosure of the date and amount of all issuances
                of
                common stock during the first and second quarters of 2005 that relate
                to
                debt conversion or other non-cash transactions. Your disclosures
                in both
                the MD&A section and Note 10 to the financial statements for the six
                months ended June 30, 2005 should be revised to explain how each
                issuance
                of shares was valued (i.e., based on the market value of the shares
                on the
                date of issuance) and accounted for in your financial
                statements.

      We
        have
        revised the issuance of all stock transactions to include how the stock was
        valued and accounted for in the financial statements, as requested.

      In
        addition, pursuant to the Commission’s request, the Company acknowledges
        that

                •

                should
                  the Commission or the staff, acting pursuant to delegated authority,
                  declare the filing effective, it does not foreclose the Commission
                  from
                  taking any action with respect to the
                  filing;

                •

                the
                  action of the Commission or the staff, acting pursuant to delegated
                  authority; in declaring the filing effective, does not relieve
                  the Company
                  from its full responsibility for the adequacy and accuracy of the
                  disclosure in the filing; and

                •

                the
                  Company may not assert this action as a defense in any proceeding
                  initiated by the Commission or any person under the federal securities
                  laws of the United States.

      Sincerely,

      /s/
        George Lovato

      George
        Lovato

      President