SecProbe.io

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Mail Stop 4561

      							May 26, 2005

Via U.S. Mail and Fax (604) 871-9919
Mr. Tim Leong
Chief Financial Officer
SE Global Equities Corp.
777 West Broadway, Suite 1200
Vancouver, BC, Canada V5Z 4J7

	RE:	SE Global Equities Corp.
      Form 10-K for the fiscal year ended December 31, 2004
		Filed March 31, 2005
		Form 10-Q for the quarterly period ended March 31, 2005
		File No. 0-26347

Dear Mr. Leong:

      We have reviewed the above referenced filings and have the
following comments.  Where indicated, we think you should revise
your
documents in response to these comments.  If you disagree, we will
consider your explanations as to why our comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your explanations.  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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 6. Management Discussion and Analysis, page 11

Recent Development - Term Sheet Signed with Sun Media, page 14

1. Tell us how you intend to account for the acquisition of Asia
Multi-Media Technology Services Holdings Limited.  In your
response,
please also clarify your use of the terms "pooling" and
"recapitalization".  Please cite the relevant guidance in your
response.

Consolidated Statements of Operations, page F-4

2. Please explain to us what direct costs represent.  Also,
describe
to us how you concluded that a gross presentation is appropriate
under EITF 99-19.

Note 3 - Loan Payable, page F-11

3. Tell us what value was assigned to the conversion feature on
October 20, 2003.  Also, explain to us how you accounted for the
conversion feature in both 2003 and 2004.

Note 4 - Capital Stock, page F-13

4. Explain to us how the expense of $64,000 discussed in this
footnote reconciles to the $181,000 on the face of the statement
of
operations.

Item 13. Exhibits, Financial Statement Schedules, and Reports on
Form
8-K, page 29

Exhibits, page 29

5. We note that the certificates filed as Exhibits 32.1 and 32.2
to
your Form 10-KSB are not in the proper form.  The required
certifications must be in the exact form prescribed; the wording
of
the required certifications may not be changed in any respect.
Certain portions of the certifications relating to internal
control
over financial reporting may be omitted as stated in Section III.E
of
SEC Release No. 33-8238.  Accordingly, please file an amendment to
your Form 10-KSB that includes the entire filing together with the
certifications of your current CEO and CFO in the form currently
set
forth in Item 601(b)(31) of Regulation S-B.  Also, please number
your
exhibits in the manner prescribed by Item 601(b) of Regulation S-
B.

*    *    *    *

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and 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 filings; 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 filings or
in
response to our comments on your filings.

      You may contact William Demarest, Staff Accountant, at (202)
551-3432 or me at (202) 551-3486 with any questions.

							Sincerely,

							Daniel L. Gordon
							Branch Chief

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Mr. Tim Leong
SE Global Equities Corp.
May 26, 2005
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