SecProbe.io

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Mail Stop 3561

      							July 27, 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
Forms 10-QSB for the Fiscal Quarters Ended January 31, 2005 and
April
30, 2005
      File No. 333-31238

Dear Mr. Pitcher:

      We have reviewed your amendments filed on June 10, 2005 as
well
as the above referenced filings and have the following comments.
As
noted in our comment letter dated May 20, 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

General

1. Given that you restated your financial statements, please file
a
Form 8-K in accordance with Item 4.02 of the Securities Exchange
Act
of 1934.

Item 8A. Controls and Procedures, page 19

2. We note your disclosure that management expects that your
disclosure controls can provide only "reasonable assurance" that
the
objectives of the controls system are met.  However it is unclear
what the point of this qualifying disclosure is when your
management
has disclosed that the company`s disclosure controls and
procedures
were deficient.  Please revise your disclosure to explain the
significance of this qualifying paragraph.

3. Please disclose any change in your internal control over
financial
reporting identified in connection with the evaluation that
occurred
during the last fiscal quarter covered by the Form 10-KSB that has
materially affected, or is reasonably likely to materially affect,
your internal control over financial reporting.  See Item 308(c)
of
Regulation S-B as well as Securities Act Release No. 33-8238
available on our website at http://www.sec.gov/rules/final/33-
8238.htm.  Please also similarly revise your Forms 10-QSB
concerning
the quarters ended January 31, 2005 and April 30, 2005.

Form 10-QSB for the Fiscal Quarter ended April 30, 2005

General

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

5. We note that you have restated for the year ended October 31,
2004.  However in your Form 10-QSB for the fiscal quarters ended
January 31 and April 30, 2005 it appears that you have not
restated
for the fiscal quarters ended January 31 and April 30, 2004.
Please
revise or advise.

Rule 13a-14(a) Certifications

6. Please amend your filing to include as exhibits 31 Rule 13a-
14(a)
certifications that 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, the form paragraph states the officers have
evaluated the effectiveness of the disclosure controls and
procedures
"as of the end of the period covered by this report" and includes
a
subparagraph (d), which you must include.  As another example, the
form refers to "internal control over financial reporting," rather
than "internal controls" in the fifth paragraph.  These are only a
few examples of the differences between your currently-filed
certifications and the form.  Please revise your certifications
generally to conform.  In addition, we note that, since you must
file
the Rule 13a-14(a) certifications with the amendment, you must
include Form 10-QSB in its entirety in your amendment.

*    *    *    *

      As appropriate, please amend your Form 10-KSB and Form 10-
QSB
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 amendments to expedite our review.  Please
furnish a cover letter with your amendments 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 comments 1, 4 and
5.
If you have questions regarding comments 2, 3 and 6, please call
Cheryl Grant, Staff Attorney, at (202) 551-3359, or 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.
July 27, 2005
Page 3

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

         DIVISION OF
CORPORATION FINANCE

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