SecProbe.io

October 3, 2005

Via US Mail and Facsimile

Mr. Patrick J. Summers
Chief Financial Officer
AIMS Worldwide, Inc.
10400 Eaton Place #450
Fairfax, VA 22030

Re: AIMS Worldwide, Inc.
 Form 10-KSB for the year ended December 31, 2004
 Form 10-QSB for the quarterly period ended June 30, 2005
 Commission File Number:  333-86711

Dear Mr. Summers:

We have reviewed the above referenced filing and have the following comments.  We have
limited our review to the financial statements and related disclosures included within these
documents.  Understand that the purpose of our  review process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filings.

Where expanded or revised disclosure is reque sted, you may comply with these comments in
future filings.  If you disagree, we will consider your explanation as to why our comments are
inapplicable or a revision is unnecessary.  In so me of our comments, we may ask you to provide
us with supplemental information so we may be tter understand your disclosure.  Please be as
detailed as necessary in your explanation.

We look forward to working with you in thes e respects and welcome any questions you may
have about any aspects of our review.

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

Financial Statements

General
1. We note from disclosure throughout your filing and in various Forms 8-K filed throughout
the year that you have acquired several comp anies.  Please explain to us how you have

Mr. Patrick J. Summ ers
AIMS W orldwide, Inc.
October 3, 2005
Page 2

evaluated these acquisitions indi vidually and in the aggregate.   Refer to Item 310 (c) of
Regulation S-B.  Your response should c over 2003 and 2004 as well as any acquisitions
during 2005.

2. As a related matter, please tell us how you have  satisfied the financial statement requirements
for any acquisitions or group of acquisitions deemed significant under Item 310 (c) of Regulation S-B.  Your response should incl ude how and when any required financial
statements were filed.  Your response shoul d cover 2003 and 2004 as well as any acquisitions
during 2005.  We may have furt her comment on your response.

Note 1. Organization, Basis of Presenta tion, and Significant Accounting Policies

Accounts Receivable, page 28
3. In our previous comment 2 in our letter  dated May 30, 2003, we asked you to include a
description of your policy with respect to a periodic review of  receivable balances and an
assessment of their collectability.  Although your current disclosure  indicates the result of
your current review, it does not address your po licy for conducting this assessment.  As such,
please revise your disclosure to discu ss your policy as previously requested.

Revenue Recognition, page 28
4. We note from your disclosure on page 28 that a substantial portion of your 2004 revenue was
earned through a cost-plus contract  with a related entity.  Suppl ementally explain the specific
terms of this contract.  Include in your res ponse the services involve d, payment terms, and
any other relevant information with respect to this contract.  We may have further comment
on your response.

Note 2. Related Party Transactions, page 29

5. We note from your disclosure on page 29 that ATB, the entity you reported as having been
acquired on April 19, 2004 in your Form 8- K filed on May 3, 2004, made advances and
investments in excess of $1.2 million during 2004.  Further, we note that these advances and
investments were written off prior to year e nd.  Supplementally explain to us the facts and
circumstances surrounding these investments and advances and their subsequent impairment.  Your response should include a timeline detailing the timing of your acquisition, when and
why these investments were made, and when the decision was made to write off these
investments.  We may have fu rther comment on your response.

6. As a related matter, please revise  your financial statements to add a note dedicated solely to
describing any acquisitions made during the period.  This disclosure shou ld address all of
requirements set forth in paragraphs 51-57 of  SFAS 141.  Please include a copy of your
intended disclosure with your response.

Mr. Patrick J. Summ ers
AIMS W orldwide, Inc.
October 3, 2005
Page 3

7. We note that you issued 1.8 million shares in January 2005 to officers in consideration for
accrued compensation of $1,123,380.  Supplementall y explain to us how the value of $0.62
per share used in this transaction compared w ith market value at the transaction date, how
you determined market value, and whether you reco rded any gain or loss on the transaction.

8. We note from your disclosure on pages 17 and 30 of your Form 10-KSB that you exchanged
1,206,220 for the extinguishment of $1,326,853 of outst anding debt and accrued interest.
However, in your discussion of recent stock transactions on page 19 of your Form 10-QSB
for the quarter ended June 30, 2005, and on page  8 of your Form 10- KSB, you state that
1,326,853 shares were exchanged for debt forgiv eness and modification in the amount of
$1,326,853.  Please explain this apparent discrepa ncy.  Your response should also address
how the stock issued was valued, how the value compared to your market value in November
2004 of $0.50 per share, as stated  in your discussion of warrant valuation in Note 6 on page
32, and whether you recorded any gain or loss on debt extinguishment.

Segments

9. We note from your Note F: Segment Informa tion on page 10 of your Form 10-QSB for the
quarter ended March 31, 2005 that you report in  three segments, Media Services, Media
Properties, and Consulting Services.  We did not, however, note any similar disclosure in
your Form 10-KSB for the year ended December 31, 2004.  Supplementally explain to us why you have not made the disclosures requ ired by SFAS 131 in your annual filing as it
appears you believe you have three reportable se gments.  We may have further comment on
your response.

Form 10-KSB for the quarterly period ended June 30, 2005

10. We note that you recorded a significant am ount of goodwill in your 2005 acquisitions of
HWL&V and Prime Time Cable.  In this rega rd, supplementally tell us what consideration
was given to recording intangible assets be fore allocating the excess purchase price to
goodwill.  See SFAS 141 and 142, as well as EITF 02-17 for guidance

11. In light of the fact the HWL&V had no assets at the time of its acquisition, supplementally
tell us how the parties arrived at the purchas e price of 500,000 shares of your common stock
along with payment of certain liabilities.

12. With respect to your acquisition of Prime Time Cable, please tell us whether its cable and
Internet systems of operated pursu ant to any contractual arrangemen ts.  If so, provide us with
a general overview of such arrangements.

Mr. Patrick J. Summ ers
AIMS W orldwide, Inc.
October 3, 2005
Page 4

13. Also, in Note B to your interi m financial statements, you refer to the historical increase in
value of subscriber contracts.  Supplementally describe these contracts and tell us how such
contracts were valued when you recorded  the acquisition of Prime Time Cable.

* * * * * * * * * * * * * * * * * * * * * * *

We urge all persons who are responsible for the a ccuracy and adequacy of the disclosure in the
filings reviewed by the staff to be certain that  they have provided a ll information investors
require.  Since the company and its management  are in possession of a ll 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 disclo sure in the filings;
‚ staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose th e 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 federa l securities laws of  the United States.

In addition, please be advised th at the Division of Enforcement has access to all information you
provide to the staff of the Division of Corporat ion Finance in our review  of your filing or in
response to our comments on your filing.

Please file your response to our comments via EDGAR within ten business days from the date of this letter.  Please understand that we may have additional comments after reviewing your
response.  You may contact Amy Geddes at  202-551-3304 or me at 202-551-3211 with any
concerns as I supervised the review of your filing.

        S i n c e r e l y ,

        David R. Humphrey
        B r a n c h  C h i e f