SecProbe.io

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Mail Stop 3561
		June 16, 2005

Trent Sommerville, President
Heartland Inc.
3300 Fernbrook Lane
Plymouth, MN 55447

	Re:      Heartland Inc.
			Form 10-KSB for Fiscal Year Ended
			December 31, 2004
			Filed March 31, 2005

Dear Mr. Sommerville:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents.  Where indicated, we think you should
revise the filing in response to these comments.  If you disagree,
we
will consider your explanation as to why our comment is
inapplicable
or revision is unnecessary.  Please be as detailed as necessary in
your explanation.

      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
filings.
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 me at the telephone number
listed
at the end of this letter.

Financial Statements

Acquisitions

1. The financial statements for the three companies acquired in
December 2004 have not yet been filed.  Financial statements of an
acquired business must be filed in an amended Form 8-K not later
than
71 calendar days after the day that the initial report on Form 8-K
must be filed.  Please file the financial statements required by
Item
310(c) of Regulation S-B immediately.

2. The company issued 1,256,000 shares of common stock to the
shareholders of Mound Technologies, Inc. ("Mound") in exchange for
all of the outstanding shares of Mound.  Prior to the transaction,
the registrant had no material operations and minimal net assets.
This transaction appears to be a capital transaction in substance,
rather than a business combination.  That is, the transaction is
equivalent to the issuance of stock by Mound for the net monetary
assets of the registrant, accompanied by a recapitalization.  The
accounting is identical to that resulting from a reverse
acquisition,
except no goodwill or other intangible asset should be recorded.
Because Mound is essentially the acquiror for accounting purposes,
the accumulated deficit of the company after the transaction
should
equal the accumulated deficit of Mound, adjusted for any
transaction
costs.  The accumulated deficit of the registrant, Inc. at the
acquisition date should be eliminated with an offsetting entry to
additional paid-in capital.  The financial statements for periods
prior to the merger should be those of Mound.  Please revise the
financial statements accordingly and provide appropriate footnote
disclosure describing the transaction and the related accounting
treatment.

3. We note the "elimination of preacquisition earnings (loss)" on
the
statement of operations. Please tell us the transactions that gave
rise to this account and provide us with your source in the
accounting literature that supports this presentation.

4. We note revenue of approximately $50 million on the statement
of
operations for the year ended December 31, 2004.  In MD&A, you
state
that sales in 2004 were a result of the acquisitions of the three
companies in 2004.  These companies were not acquired until the
end
of December 2004, and thus it appears that you may have recorded
the
revenues from the three companies prior to your acquisition of
them.
Please refer to SFAS 141 and revise your statements of operations
accordingly.

Note N - Litigation

5.  You state that the company is contingently liable for
$428,000.
Please revise to clarify if this amount is recorded in the
financial
statements.  Refer to SFAS 5.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the registrant and its management are
in
possession of all facts relating to a registrant`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 registrant acknowledging that:
* the registrant 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 registrant 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 the applicable amended Forms and a supplemental
letter in response to these comments on EDGAR on or before July 8,
2005.  Please understand that we may have additional comments
after
reviewing your amendment and responses to our comments.

      You may contact Babette Cooper at (202) 551-3396 or me at
(202)
551-3871 if you have any questions.

Sincerely,

Tia Jenkins
Senior Assistant Chief Accountant
Office of Emerging Growth Companies

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Trent Sommerville
Heartland Inc.
June 16, 2005
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