SecProbe.io

October 26, 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 your October 10, 2005 re sponse letter and ha ve the following
comments.  Where expanded or revised disclosu re is requested, 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 unnece ssary.  We also ask you to provide us with
supplemental information so we may better understa nd your disclosure.  Please be as detailed as
necessary in your explanation.  We look forward to working with you in these respects and
welcome any questions you may have about any aspects of our review.

* * * * * * * * * * *
Note 1: Organization, Basis of Presen tation, and Significant Accounting Policies

Revenue Recognition, page 28
1. Refer to our previous comment 4.  Supplementa lly explain to us the literature you relied upon
in reaching the conclusion that net treatment of reimbursed expenses was appropriate.  In
your response, tell us what consideration was given to the guidance in EITF 01-14.

Note 2: Related Party Transactions, page 29

2. We note from your response to our previous comments 7 and 8 that you have taken a 33%
discount off the market price of your common stoc k.  It appears that this discount, given the
restrictions in place on your common stock, is  excessive.  As such, please reperform your
analysis of the financial impact of this trans action.  If you feel there are additional measures

Mr. Patrick J. Summ ers
AIMS W orldwide, Inc.
October 26, 2005
Page 2

supporting $0.62 as the appropriate market value for the stock exchanged in this transaction,
supplementally explain how these measures we re identified and why you feel they are
appropriate.  We may have fu rther comment on your response.

3. Refer to our previous comment 8.  Please revise your disclosu re to include the facts and
circumstances surrounding the extinguishment of debt as discussed in your response to our previous comment 8.

Form 10-QSB for the Quarterly Period Ended June 30, 2005

4. Please confirm to us that the contracts discus sed in response to our comment 12 make up the
“renewable customer base” discussed in your re sponse to our previous comment 10.  If these
are separate, please explain to us why you have not assigned a value to these relationships as
well as it appears the renewable nature of thes e contracts impacts both the current earnings
value of operations and the earnings potential  of future operations , and they meet the
definition of an intangible a sset as described in SFAS 142.

5. Your response to our prior comment 11 appears to address only the reasons why you wished
to acquire HW&L, and not the manner in which the amount of consideration was determined.
As such, supplementally explain to us how the consideration of 500,000 shares of common
stock with assumption and/or payment of certain  liabilities was negotia ted or determined.
We may have further comment on your response.

6. As a related matter, we note that you have al located the entire purchase price of HW&L to
goodwill.  Please note that, according to paragraph A14(a)(1) of appendix A to SFAS 141, trade names are considered intangible assets.  As such, please reclassify the trade name
acquired to intangible assets and assign this asse t a useful life.  Your response should include
a discussion of how you determined the useful life associated with this assets, and your
assessment of the impact on earnings on a quart er by quarter basis si nce the acquisition.

7. Refer to our previous comments 10, 12, and 13.  We note that you determined the primary value of the acquisition was th e earnings value of operations  in place and the earnings
potential of operations in place.  We also note there appears to be seve ral types of contracts
and customer lists acquired as part of th e PTC acquisition, and then may currently or
potentially contribute to earnings.  Supplementally list each type of contract that was
acquired in the Prime Time Cable acquisition, the remaining terms or range of remaining
terms, and why you feel the fair value of such arrangements would not qualify as an
intangible asset. If you concl ude that it should be classified  as an intangible asset,
supplementally explain to us how you determined  its useful life, and revise your financial
statements to include the di sclosures required by paragrap hs 42-47 of SFAS 142.

8. As a related matter, supplementally explain to us why you have included the non-compete
agreement cited in your response to our prev ious comment 13 in goodwill and not intangible
assets.  Your response should include your assessme nt of fair value and the material terms of

Mr. Patrick J. Summ ers
AIMS W orldwide, Inc.
October 26, 2005
Page 3

the non-compete agreement, included expirati on date. We may have further comment on
your response.
* * * * * * * * * * *
As appropriate, please respond to these comments  within 10 business days or tell us when
you will provide us with a response.  If an am endment is required, you may wish to provide us
with marked copies of the amendment to exped ite our review.  Please en sure your response letter
keys your responses to our comments and provides any requested supplemental information as this greatly facilitates our re view.  Please understand that we may have additional comments
after reviewing your amendment and responses to our comments.

  We urge all persons who are responsible fo r the accuracy and adequ acy 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 comp any and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.

 In connection with responding to our comme nts, 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 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 federa l securities laws of  the United States.

In addition, please be advi sed that the Division of Enforcement has access to all
information you provide to the staff of the Divisi on of Corporation 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 additi onal 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