SecProbe.io

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								November 16, 2005

Mr. Levi Mochkin
President and Chief Executive Officer
Avenue Group, Inc.
405 Lexington Avenue, 26th Floor
New York, NY 10174

	Re:	Avenue Group, Inc.
		Form 10-KSB for the Fiscal Year Ended December 31, 2004
Filed May 20, 2005
		Response letter dated October 27, 2005
      File No. 000-30543

Dear Mr. Mochkin:

      We have reviewed your response letter and filings and have
the
following comments.  We have limited our review to those issues we
have addressed in our 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.

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

Critical Accounting Estimates, page 23

1. In the proposed disclosure related to the Black-Scholes pricing
model within your response to comment 1, you explain that there
are
inherent uncertainties related to the use of the model that are
widely discussed in the press.  As this is the case, focus your
disclosure on the specific estimates and uncertainties experienced
by
you rather than on those inherent in the pricing model.

2. Your proposed disclosure related to the reasons the current
estimates do not compare with past estimates is vague and does not
explain to the reader what has changed and how this may impact
future
earnings.  Please revise the disclosure to discuss the specific
facts
and circumstances that have changed, and the potential impact to
you.

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

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

3. Your response to previous comment 2 regarding your accounting
policy for oil and gas operations states that you apply the
provisions of SFAS 143 for dismantlement and abandonment cost.
However, we are unable to locate the disclosures required by SFAS
143
paragraph 22.  As such, please revise your document to include
these
disclosures.

4. We note your proposed disclosure related to DD&A recorded on
the
Karakalise #1 well which explains that you produced a small
quantity
of hydrocarbons from the well, and recorded DD&A using a rough
estimate of reserves you believe you will produce.  SFAS 19
paragraph
35 requires unit-of-production amortization be computed on the
basis
of proved developed reserves rather than a rough estimate.  Please
revise your policy disclosure, and if necessary, the amounts
recorded
in the financial statements to be consistent with the requirements
of
SFAS 19.  Please also confirm that your reserves are in fact
proved,
as that term is defined in Regulation S-X, Rule 4-10 (a).
Finally,
revise the disclosure to explain where depreciation and
amortization
is presented on the face of the financial statements.

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

5. In your table calculating the gain on disposition of Bickhams
media, you show a value for the 4 million shares of ROO Media
common
stock received of $140,000.  This amount appears to be equated as
4
million shares times the market price, less a 50% discount.  In
your
response to our previous comment 5, you indicated that you should
have used the full quoted market price as the best estimate of
market
value for the ROO Media shares you own.  As such, please revise
your
table and corresponding amounts in the financial statements to
reflect the full market value of the shares received in
conjunction
with the sale of Bickhams Media, or explain to us why you believe
it
is appropriate to apply a 50% discount in recording the
transaction.

Note 9 - Capitalization, page F-18

(B) Common Stock, page F-18

6. Your proposed disclosure related to the decline in value of
your
investment in Langley Park Investment Trust did not include a
detailed explanation of the purpose, underlying economics, and
your
relationship with the Langley Park Investment Trust.  Nor did it
include 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.  As such,
please revise your proposed disclosure to include the above
discussion points, as well as your overall ownership percentage of
Langley Park Investment Trust.

7. We note your response to comment 7 related to the Langley
shares
held in escrow.  Please explain to us how you evaluated the
provisions of SFAS 133 in determining the appropriate accounting
for
this agreement.  If necessary, please contact us regarding the
treatment of the shares held in escrow.

Engineering Comments

Risk Factors, page 2

8. Regarding response number 10, it does not appear that any of
your
management has technical training or expertise in the areas of
petroleum engineering or geology.    Amend your document to
provide a
risk factor stating this risk and the impact it may have on your
results.

The Company, page 7

9. Regarding your response number 11, if the information available
is
too limited to declare proved reserves, it is inappropriate to
state
that you believe your well will be commercial.  Amend your
document
to state that you are working to obtain additional data in order
to
make a determination whether the well contains proved reserves.
In
addition, be advised that in order to declare proved reserves, you
must have access to a market.

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.

      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. Levi Mochkin
Avenue Group, Inc.
November 16, 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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