SecProbe.io

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								September 2, 2005

Mr. Yam-Hin Tan
Chief Financial Officer
Avenue Group, Inc.
17547 Venturs Blvd, Suite 305
Encino, CA 91316

	Re:	Avenue Group, Inc.
		Form 10-KSB for the Fiscal Year Ended December 31, 2004
Filed May 20, 2005
		Form 10-QSB for Fiscal Quarter Ended March 31, 2005
      Filed June 10, 2005
		File No. 000-30543

Dear Mr. Tan:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents. 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.

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Critical Accounting Estimates, page 23

1. You have identified several items you regard as critical due to
the estimates and assumptions involved in the valuation of these
items.  Your current disclosure appears to be more descriptive of
general accounting policies utilized, rather than the
uncertainties
underlying your specific estimates and assumptions.  Please revise
your disclosures to address the following:

* reasons you consider the items identified to be critical,
* material assumptions underlying your critical estimates,
* analysis of the uncertainties involved, in terms of the
variability
in earnings and cash flow, that is reasonably likely to result in
resolution,
* analysis of how the facts and circumstances underlying your
critical estimates compare to those associated with past
estimates,
and the degree of accuracy with which you have made these
estimates
in the past, and
* analysis of your specific sensitivity to change based on
outcomes
that are reasonably likely to occur and have a material effect.

You should provide both quantitative and qualitative disclosure
when
material to investors, and identify instances where you have
changed
assumptions and estimates in the past, and explain how these
changes
impacted your financial statements.  Please refer to FRC Section
501.14 if you require further guidance.

Financial Statements

Note 2 - Summary of Significant Accounting Policies, page F-9

(G) Investment and Oil and Gas Operations, page F-10

2. Although you state that you account for your investment in
Turkish
oil leases "under the cost method of accounting," further details
of
your methodology are necessary to discern the extent to which it
corresponds to one that is acceptable under GAAP.  As you may
know,
current GAAP literature allows for two different methods of
accounting for oil and gas producing activities.  You may utilize
either the full cost method described in Rule 4-10(c) of
Regulation
S-X, which would require that you disclose information incremental
to
that you have presented in your filing; or the successful efforts
method described in SFAS 19.  The disclosure requirements set
forth
in SFAS 69 apply under either method.  Please revise your
disclosures
to describe in greater detail the method of accounting you are
applying to your oil and gas operations.

Note 3 - Investment in ROO Group, Inc., page F-14

3. Please describe to us the nature of operations for Bickhams
Media,
Inc. and Videodome Networks, Inc.  As part of your description,
include a discussion of whether the two entities are considered a
business for accounting purposes.  Also explain how you accounted
for
your interest in Videodome prior to its disposition.

4. Please expand your disclosure to include a tabular presentation
of
the calculation you made in determining the gain on sale of
discontinued operations of $584,874, including the book value of
the
subsidiary conveyed.  Reconcile the total value assigned to the
various elements, which you indicate includes a cash component, to
the corresponding figure identified in its entirety as non-cash on
page F-8.

Given that the value you ascribed to the shares of ROO Media
received
in the various transactions described would have presumably
included
the value of the registration rights accompanying those shares,
explain the reasons you believe it is appropriate to recognize a
$105,000 gain upon receiving an additional 13,000,000 shares in
exchange for releasing ROO Media of the registration requirement.

On a related point, since you retained an indirect interest in the
assets transferred to ROO Media by way of your 25 percent equity
interest in that entity, it is not clear that you have
relinquished
the rights and rewards of ownership.  Tell us the accounting
literature that you have relied upon in calculating the gains, and
which you believe supports the method of accounting that you have
applied.

5. We note that you have applied a discount of 50 percent from
market
value in recording your investment in ROO Media, which takes into
account several factors.  We generally believe that quoted market
prices or, if unavailable, prices based on proximate private
placements, are the best estimate of fair market value and should
be
used if available.  Tell us how you determined that your
calculation
resulted in an appropriate valuation of the ROO Media shares;
provide us with a detailed explanation of how you arrived at the
discount applied to each factor identified.

6. Explain the reasons you believe the accounting policy you
describe
on page F-10, indicating that your ROO Group securities are
characterized as available for sale, and reported at market value,
complies with the guidance in footnote 2 to paragraph 3(a)of SFAS
115, which generally excludes restricted stock from the provisions
of
SFAS 115.  Under these circumstances, we would ordinarily expect
your
restricted stock to be recorded at historical cost under the
provisions of APB 18.

Note 9 - Capitalization, page F-18

(B) Common Stock, page F-18

7. Expand the disclosure surrounding the Langley Park Investment
Trust to include a detailed explanation of the purpose, underlying
economics, and current status of the transaction and your
relationship with the Langley Park Investment Trust.  Address the
reasons for the decline in value of Langley stock that caused you
to
take an impairment charge of approximately $9.4 million,
representing
an 85 percent decline in value, against your investment less than
six
months from its origination.  Explain how you are accounting for
the
value guarantee mentioned, and quantify the effects that are
reflected in your financial statements.

Note 13 - Subsequent Events, page F-23

Separation Agreement, page F-23

8. Expand your disclosure concerning the Separation Agreement with
Mr. Herzog to include a detailed explanation of the purpose and
underlying economic reasons that you agreed to surrender
12,500,000
ROO Media shares, in addition to paying $125,000, to reacquire
10,000,00 shares of your common stock.  Explain how you valued
each
component.  Tell us the accounting literature that you believe
supports gain recognition on the reacquisition of your common
stock.
Describe the facts and circumstances under which Mr. Herzog
"agreed
to resign" (identify the reasons he was asked to resign).  Also
explain the purpose of structuring the arrangement in a manner
that
called for you and Mr. Herzog to exchange $125,000 payments;  tell
us
the dates that your payment was withdrawn from your account, and
the
cash receipt was deposited to your account.

Form 10-QSB for the Fiscal Quarter Ended March 31, 2005

General

9. We believe that you will need to amend your interim report on
Form
10-QSB, along with your Form 10-KSB, in order to fully address the
concerns raised in the comments included in this letter.  However,
we
ask that you contact us to discuss these matters prior to filing
your
amendments at your earliest convenience.  Further, as you have not
filed your second quarter report on Form 10-QSB, we wish to remind
you of your reporting obligations under Rule 13a-13 of Regulation
13A.

Engineering Comments

Form 10-KSB for the Fiscal Year Ended December 31, 2004

Risk Factors, page 2

10. It does not appear that any of your management has any
practical
experience in the oil and gas industry.  Provide a risk factor
stating this risk and the impact it may have on your results.

The Company, page 7

11. You state that you made your first commercial oil discovery in
September 30, 2003 on the Karakilise license.  However, under MD&A
you state it is only a potentially commercial discovery and that
due
to the limited amount of geological information available there
has
been no determination made as to any reserve estimates.  Revise
your
document so as to not give the impression you have made a
commercial
discovery when you have not.

General

12. Revise your document to include all the requirements of
Industry
Guide 2 and FASB 69.

Closing Comments

      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.

      You may contact Mark A. Wojciechowski at (202) 551-3759 or,
in
his absence, Karl Hiller at (202) 551-3686 if you have questions
regarding comments on the financial statements and related
matters.
You may contact James Murphy, Petroleum Engineer, at (202) 551-
3703
if you have questions related to engineering issues and related
disclosures.  Please contact me at (202) 551-3740 with any other
questions.

								Sincerely,

								H. Roger Schwall
								Assistant Director

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Mr. Yam-Hin Tam
Avenue Group, Inc.
September 2, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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