SecProbe.io

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Mail Stop 3561
		October 14, 2005

Louis Pardau Dit Pardo
President
Poseidis Inc.
222 Lakeview Avenue, PMB 160
West Palm Beach, FL 33401

Re:	Poseidis Inc.
	Preliminary Information Statement on Schedule 14C
	Filed September 28, 2005
	File No. 0-26329

Dear Mr. Pardo:

      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
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Outstanding and Issuable Securities, page 4

Standby Equity Distribution Agreement, page 4
1. To allow investors to better understand the dilutive effect of
the
Standby Equity Distribution Agreement, please include a tabular
presentation showing the number of shares issuable at the current
market price and at a 25%, 50% and 75% decrease in the current
market
price.  Also, disclose the maximum number of shares that may be
issued and the percentage of outstanding securities that this
amount
represents as well as the percentages of outstanding securities
represented by the securities issued at the discounts to market
price
described above.
2. According to your form 8-K dated August 26, 2005 and the
Standby
Equity Distribution Agreement, you have agreed to pay Cornell
Capital
5% of the proceeds that you receive from each advance under the
agreement.  Please disclose this 5% payment and describe how this
payment fits within the equity line arrangement.
3. It appears from the relevant exhibits to the form 8-K dated
August
26, 2005 that David Gonzalez, Esq. will act as escrow agent in
connection with the standby equity distribution agreement.
Currently, however, we note that Mr. Gonzales is a managing
partner
of Cornell Capital.  In view of the affiliate relationship between
Cornell Capital as investor and Mr. Gonzalez as escrow agent, it
appears that Cornell Capital may have actual or potential
discretion
as to whether it will perform its obligation under the standby
equity
distribution agreement.  Please provide us with your analysis as
to
whether this affiliate relationship is inconsistent with our
position
regarding equity lines of credit set forth in the March 31, 2001
Quarterly Update to our Current Issues and Rulemaking Projects
Outline.

Convertible Debenture, page 5
4. Your disclosure is confusing as to the relationship between the
12% convertible debentures, the warrants and the standby equity
distribution agreement, each of which you entered into with
Cornell
Capital Partners.  In particular, the purpose for issuing the
convertible debentures and warrants given the existing standby
equity
distribution agreement is unclear.  Further, please provide us
with
your analysis as to whether the private transaction under the
equity
line will be completed, prior to the filing of the resale
registration statement, given the terms and existence of the
convertible debentures and the warrants.  Please see the March 31,
2001 Quarterly Update to our Current Issues and Rulemaking
Projects
Outline.  We may have further comment upon review of your
response.
5. We note your disclosure that the conversion price for the 12%
convertible debenture is $0.0497 per share.  It appears, however,
that this conversion price may be adjusted pursuant to the terms
of
the debenture.  Please fully disclose the circumstances in which
the
conversion price may be adjusted and how the conversion price
would
be adjusted for each circumstance.  Further, we note your
disclosure
that you may issue an additional $150,000 in principal of the 12%
debenture to Cornell Capital "[u]pon the satisfaction of certain
conditions."  Please expand your disclosure to clearly set forth
the
"certain conditions."  Please also disclose the conversion price
and
adjustment terms, if any, for this debenture.  If the conversion
price and adjustment terms are identical to the initial $150,000
debenture, please so state.  We may have further comment upon
review
of your response.
6. We note your disclosure that interest on the 12% debenture may
be
payable in common stock at the option of Cornell Capital.  Please
disclose the price per share to be used in determining the number
of
shares to be paid for the interest component of the debenture.
Please also disclose the conditions under which Cornell Capital my
request that the interest be paid in common stock.

Warrants, page 5
7. We note your disclosure that you issued Cornell Capital
warrants
to purchase 500,000 and 1,250,000 shares of common stock at an
exercise price of $0.12 per share.  According to the warrant
agreements, filed as exhibits 99.1 and 99.3 to the form 8-K dated
August 26, 2005, however, it appears that the exercise price of
$0.12
may be adjusted per section 8 of the agreements.  Please expand
your
disclosure to fully discuss the conditions for adjusting the
exercise
price.

* * *

       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 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 contact Kurt Murao, Attorney Advisor, at (202) 551-
3338,
or Ellie Quarles, Special Counsel, at (202) 551-3238 if you have
questions regarding the comments.

      Sincerely,

						H. Christopher Owings
      					Assistant Director

cc: 	Deborah Carroll, Esq.
	Gallagher, Briody & Butler
	Fax: (609) 452-0090

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Louis Pardau Dit Pardo
Poseidis Inc.
October 14, 2005
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