SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Room 4561

	July 19, 2005

Robert S. Stefanovich
Chief Financial Officer
Artemis International Solutions Corporation
4041 MacArthur Boulevard, Suite 401
Newport Beach, California 92660

Re:	Artemis International Solutions Corporation
	Post-effective Amendment No. 1 to Form S-1
	File No. 333-117487

	Form 10-K for the year ended December 31, 2004
	Form 10-Q for the quarter ended March 31, 2005
	File No. 0-29793

Dear Mr. Stefanovich:

      This is to advise you that we have limited our review of the
above filings to the matters addressed in the comments below.  No
further review of the filings has been or will be made.  Please
respond to our comments that pertain to the periodic filings
within
10 business days of the date of this letter.  All persons who are
by
statute responsible for the adequacy and accuracy of the
registration
statement are urged to be certain that all information required
under
the Securities Act has been included.

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

Form 10-K for the year ended December 31, 2004

Item 9A. Controls and Procedures

1. You state that an internal control system "can provide only
reasonable, not absolute, assurance that the objectives of the
control system are met."  In your response letter, tell us whether
your disclosure controls and procedures are designed to provide
reasonable assurance of achieving their objectives and whether
your
chief executive officer and chief financial officer concluded that
your disclosure controls and procedures are effective at that
reasonable assurance level.  Please refer to Section II.F.4 of
Release No. 33-8238 for additional guidance.

2. We note that you evaluated the effectiveness of your disclosure
controls and procedures as of a date within 90 days prior to the
filing of your report.  The evaluation of your disclosure controls
and procedures pursuant to Rule 13a-15(b) under the Exchange Act
is
to be made as of the end of each fiscal quarter.  Please advise us
whether your disclosure controls and procedures were effective as
of
December 31, 2004 and, with respect to your subsequent periodic
filing, March 31, 2005.

3. Your disclosure with respect to any changes in your internal
control over financial reporting does not meet the requirements of
Item 308(c) of Regulation S-K.  For example, your disclosure
states
that "there were no significant changes made in [y]our internal
controls over financial reporting."  Item 308(c) requires the
disclosure of any change that occurred during the quarter that has
materially affected, or is reasonably likely to materially affect,
your internal control.  Please confirm that for the quarter ended
December 31, 2004 there were no changes in your internal control
over
financial reporting that occurred during the quarter that
materially
affected, or were reasonably likely to materially affect, your
internal control over financial reporting.  This comment also
applies
to your subsequent periodic filing.  Please see Item 308(c) and
Release No. 33-8328 for additional guidance.

4. Please confirm that you will note the foregoing comments when
preparing your periodic filings.

*              *              *              *

      As appropriate, please amend your filings in response to
these
comments.  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 supplemental 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 related to your disclosure, they are
responsible for the accuracy and adequacy of the disclosures they
have made.

      Prior to our declaration of the effective date of the
pending
post-effective amendment pursuant to Section 8(c) of the
Securities
Act, the company should furnish a letter acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert the staff comments and the
declaration
of effectiveness 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 connection with our review of
your
filing or in response to our comments on your filing.

      You may contact Daniel Lee at (202) 551-3477 with any
questions.  If you need further assistance, you may contact me at
(202) 551-3462.

	Sincerely,

	Mark P. Shuman
	Branch Chief - Legal

cc:	Via Facsimile
	Robert S. Matlin, Esq.
	Thelen Reid & Priest LLP
	875 Third Avenue
	New York, New York 10022
	Telephone: (212) 603-2215
	Facsimile:  (212) 603-2001

</TEXT>
</DOCUMENT>