SecProbe.io

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Mail Stop 4561
      September 8, 2005

VIA U.S. MAIL AND FAX

Mr. Michael Rider
Chief Executive Officer
BellaVista Capital, Inc.
420 Florence Street
Suite 200
Palo Alto, CA  94301

      Re:	BellaVista Capital, Inc.
      Item 4.01 Form 8-K
      Filed September 2, 2005
      File No. 000-30507

Dear Mr. Rider:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document 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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may 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 numbers
listed
at the end of this letter.

Form 8-K filed September 2, 2005

1. We note that the second paragraph of your Item 4.01 disclosure
addresses only the last report of your accountant when Item
304(a)ii
of Regulation S-K requires that you address the accountant`s
report
for the past two years.  Please revise your Form 8-K accordingly.

2. We note that the second paragraph of your Item 4.01 disclosure
does not specifically address the two most recent fiscal years and
any subsequent interim period preceding the resignation of your
former accountant.  Revise your Form 8-K to provide your
disclosure
for those periods specifically required by Items 304(a)(iv) and
(v)
of Regulation S-K.  Please file a revised Exhibit 16 letter.

      File an amendment under cover of Form 8-K/A and include the
Item 4.01 designation, including the letter from the former
accountant filed as an Exhibit 16.  Please note that your former
accountants should make it clear within the Exhibit 16 letter that
it
is in reference to your amended 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 provide the supplemental information requested above
within 5 business days from the date of this letter.  The
supplemental information should be filed as correspondence on
EDGAR.
The amendment requested should be filed as promptly as possible
and
should be reviewed by the former accountants.  The letter required
by
Exhibit 16 should cover any revised disclosures.

Any questions regarding the above should be directed to me at
(202)
551-3439.

								Sincerely,

								Howard Efron
								Staff Accountant

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BellaVista Capital, Inc.
September 8, 2005

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