SecProbe.io

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Mail Stop 0407

      							May 20, 2005

Via U.S. Mail and Fax (1-858-279-1799)
Mr. Todd M. Pitcher
Interim Chief Financial Officer
Superclick, Inc.
5001 LBJ Freeway
Suite 700 PMB 173
Dallas, TX  75244

	RE:	Superclick, Inc.
      Form 10-KSB for the fiscal year ended October 31, 2004
		Filed January 28, 2005
		File No. 333-31238

Dear Mr. Pitcher:

      We have reviewed your amendments filed on dated April 29,
2005
as well as the above referenced filings and have the following
comments.  As noted in our comment letter dated March 16, 2005, we
have limited our review to your financial statements and related
disclosures and will make no further review of your documents.  As
such, all persons who are responsible for the adequacy and
accuracy
of the disclosure are urged to be certain that they have included
all
information required pursuant to the Securities Exchange Act of
1934.
Where indicated, we think you should revise your documents 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.

Form 10-KSB/A for the fiscal year ended October 31, 2004

Item 6 Managements Discussion and Analysis of Financial Condition
and
Results of Operations

Results of Operations

1. Update your results of operations to reflect the restated
financial statements.

The Company`s Liquidity Plan

2. Refer to your statement that during the latter half of Quarter
4,
2004, the Company`s cost control strategies focused on general and
administrative expenses.  These cost control strategies were the
primary reason the Company was able to produce cash flow from
operations.  Also refer to your Consolidated Statement of Cash
Flows
on page 7 which states that you have a cash outflow from operating
activities of $(867,513).  Please revise your liquidity discussion
to
discuss your cash flow from operations for the year ended October
31,
2004.  In addition include a discussion of investing and financing
cash flow activities.  Finally provide a discussion of your going
concern opinion and how you plan to finance your operations for
the
next 12 months.

For additional guidance, please refer the Commission`s
Interpretive
Release on Management`s Discussion and Analysis of Financial
Condition and Results of Operation which is located on our website
at:  http://www.sec.gov/rules/interp/33-8350.htm.

Consolidated Statements of Operations, page 4

3. It appears that you recorded gain of forgiveness of debt of
$299,441 for the year ended October 31, 2004 and 2003
respectively,
however you do not have anything recorded for gain on forgiveness
of
debt from inception to October 31, 2004.  This appears to be a
typographical error.  Please revise or advise.

Note A - Organization and Summary of Significant Accounting
Policies

Revenue recognition policy, page 12

4. Refer to your Management`s Discussion and Analysis where you
state
that the company derives the majority of its revenue from
installation of its Superclick Internet Access Management System
and
fees for the maintenance, continuing call center support, and
improvements to the system.  In this regard:
* Tell us and disclose, citing accounting literature used, your
accounting policy regarding revenue recognition for maintenance
fees,
call center support, and improvements to the system.
* Tell us how you considered EITF 00-21.
* Tell us how your considered Item 5-03(b) of Regulation S-X with
regard to separate disclosure for different types of revenues and
cost of revenues.

Note I - Related Party Transactions, page 28

5. We note that during the year ended October 31, 2003 that
Superclick Inc. forgave $130,000 it had previously advanced
Superclick Networks, Inc.  We also note that you recorded that as
gain on forgiveness of debt in your Consolidated Statement of
Operations.  Considering that you fully consolidated Superclick
Networks, Inc. and Superclick Inc., tell us why a gain on
forgiveness
of intercompany debt is recorded in your Consolidated Statement of
Operations.

Note M - Restatement, page 36

6. We note your statement that "in their letter dated, March 16,
2005
the SEC determined the acquisition of Superclick Netwworks, Inc.
was
a reverse merger."  In that respect we remind you that our letter
states that "it appears that the acquisition of Superclick
Networks,
Inc. should have been accounted for as either a reverse
acquisition
or a recapitalization."  Given that these financial statements are
your responsibility, please revise your statement.

Item 8A. Controls and Procedures

7. In view of the determination that your accounting was
inconsistent
with the accounting literature and revision of the financial
statements, it appears that your disclosure controls and
procedures
were ineffective as of December 31, 2004 and for your subsequent
completed quarterly periods.  Please revise, or tell us why you
believe they are effective.

Exhibits

8. Please amend your certifications to conform exactly to the form
provided for in the revised rules release effective August 14,
2003.
See Item 601(b)(31) of Regulation S-B and Securities Act Release
No.
33-8238 (June 5, 2003).  For example, concerning the third
paragraph,
the form states that "disclosure controls and procedures" is
defined
in Exchange Act Rules 13a-15(e) and 15d-15(e), not Rules 13(a)-
14(c)
and 15d-14(c).  In addition, we note that, since you must file the
Rule 13a-14(a) certifications with the amendment, you must include
Form 10-KSB in its entirety in your amendment.  Also, revise the
certifications that were filed as exhibits to your subsequent Form
10-QSB/A.

Form 10-QSB/A for the quarterly period ended January 31, 2005

General

9. Revise to comply with the above comments to the extent
applicable.

Consolidated Balance Sheet, page 3

10. We note that you had $256,896 recorded as deferred revenue as
of
October 31, 2004.  However, as of January 31, 2005 it appears that
you do not have any deferred revenue recorded.  Please explain,
citing accounting literature used.

Note L - Subsequent Events, page 21

11. Tell us about your cashless options exercised subsequent to
January 31, 2005 and how you account for them, citing accounting
literature used.  Tell us how many of your options issued have a
cashless exercise feature.

Item 3. Controls and Procedures, page 33

12. Revise to apply the definition of disclosure controls and
procedures found in Rules 13a-15(e) and 15d-15(e), which became
effective on August 14, 2003.  Your current disclosure references
Rules 13a-14(c) and 15d-14(c).  See Securities Act Release No. 33-
8238 (June 5, 2003).

13. Furthermore, it is not clear whether, in making their
conclusions
in your subsequent Form 10-QSB/A, your certifying officers
considered
all information described in the definition of disclosure controls
and procedures in Exchange Act Rule 13a-15(e).  Please disclose
whether your certifying officers concluded, as of the end of the
period covered by each report, that your disclosure controls and
procedures were effective in ensuring that information required to
be
disclosed by you in the reports that you file or submit under the
Exchange Act is recorded, processed, summarized and reported,
within
the time periods specified in the Commission`s rules and forms.
Also
disclose whether your certifying officers concluded that your
disclosure controls and procedures were effective to ensure that
information required to be disclosed in the reports that you file
or
submit under the Exchange Act is accumulated and communicated to
your
management, including your certifying officers, to allow timely
decisions regarding required disclosure.  See Exchange Act Rule
13a-
15(e).

Alternatively, you may simply disclose, if true, that your
certifying
officers concluded that, as of the end of the period covered by
the
report, your disclosure controls and procedures were effective.

14. In addition, it is not clear in your disclosure in the 10-
QSB/A
whether the problems with internal controls amounted to material
weaknesses.  Please revise to state whether you have determined
the
deficiencies were significant deficiencies that, individually or
in
the aggregate, constituted material weaknesses in your internal
control over financial reporting.  If the deficiencies constituted
material weaknesses, tell us what the weaknesses were, when they
existed, and the bases for your certifying officer`s conclusions
about the effectiveness of your disclosure controls and procedures
in
light of the material weaknesses.  Please see Question 11 of
Management`s Reports on Internal Control over Financial Reporting
and
Certification of Disclosure in Exchange Act Periodic Reports
Frequently Asked Questions (revised October 6, 2004) available on
our
web site at
http://www.sec.gov/info/accountants/controlfaq1004.htm.

*    *    *    *

      As appropriate, please amend your Forms 10-KSB 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 supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

      You may contact Inessa Berenbaum, Staff Accountant, at (202)
551-3371 or Carlos Pacho, Senior Assistant Chief Accountant, at
(202)
551-3835 if you have questions regarding the financial statements
and
related matters.  Please contact me, at (202) 551-3810 with any
other
questions.

							Sincerely,

							Larry Spirgel
							Assistant Director

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Mr. Todd M. Pitcher
Superclick, Inc.
May 20, 2005
Page 5

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

         DIVISION OF
CORPORATION FINANCE

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