SecProbe.io

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June 9, 2005

                                            Via U.S. Mail and Fax (202) 942-9594

Mr. Larry Spirgel
Assistant Director
Division of Corporation Finance
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Mail Stop 0407
Washington, D.C. 20549

RE:      Superclick, Inc. Amended Filings
         Form 10-KSB/A for the fiscal year ended October 31, 2004
         Form 10-QSB/A for the quarter ended January 31, 2005
         File No. ___________________

Dear Mr. Spirgel,

This letter is in response to your letter dated May 20, 2005 regarding your
review of the above referenced financial statements and your comments thereon.
We have enclosed the following:

      1.    An amended Form 10-KSB for the fiscal year ended October 31, 2004,
      2.    A redlined version of Form 10-KSB for the fiscal year ended October
            31, 2004
      3.    An amended Form 10-QSB for the quarter ended January 31, 2005
      4.    A redlined version of Form 10-QSB for the quarter ended January 31,
            2005

In regard to your comments pursuant to the 10-KSB,

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

In the Management's Discussion and Analysis, we have updated the results of
operations to reflect the restated financial statements.

Comment 2 - 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.

We have revised our liquidity discussion in the section entitled "The Company's
Liquidity Plan" in the MD&A to further discuss cash flow from operations
recognizing that the cash outflow from operating activities for the year ended
October 31, 2004 was $(848,246). We have also included a discussion of investing
and financing cash flow activities for the year ended October 31, 2004, as well
as a discussion of our independent registered public accounting firm, Bedinger &
Company's "going concern" comment on our Company and the Company's intention to
continue to finance operations for the foreseeable future through further equity
and/or debt financing instruments. We recognize that the Company cannot
guarantee that it will be successful in these efforts.

<PAGE>

Comment 3 - It appears that you recorded gain on forgiveness of debt of $299,441
for the year ended October 31, 2003. However, the total does not carry to the
since inception column.

The gain on forgiveness of debt should have been stated at $169,441, which
represents the forgiveness of three notes from Superclick Networks, Inc. that
were forgiven during the fiscal year ended October 31, 2003. The additional
amount of $130,000 represents the forgiveness by Superclick, Inc. of the note
from Superclick Networks, Inc. The $130,000 should have been eliminated during
consolidation. This was an error on our part and has been corrected in the
restated financial statements for the Years Ended October 31, 2004 and 2003.

Comment 4 - Please discuss and disclose accounting policy regarding revenue
recognition for maintenance fees, call center support and improvements to the
system.

We recognized the maintenance and upgrade revenue at the time of renewal or
installation as the fee was non-refundable and the upgrade/maintenance portion
of the fee was estimated to be a minimal portion of the revenue (4% in 2002 and
1% in 2003). In the beginning Superclick Networks, Inc. customer support was
provided on a best effort basis and constituted a minimal part of contract
sales. The equipment and technical element of the sales were also charged at
lower than other vendor's in similar industry to facilitate breaking into the
market and establishing a name for the Company. Until the fiscal year ended
October 31, 2004 the customer support department was small and facilitation by
customers was negligible. Upgrades consisted of patches to software applications
where a deficiency was detected and were minimal and infrequent. During the end
of fiscal year 2003 the Company reevaluated charges for maintenance and upgrades
and based its pricing on other vendor's charges for similar services. Those
items taken together were perceived to be de minimus and the deferral of revenue
for years ended October 31, 2003 and 2002 were deemed to be immaterial.

As we have grown our revenue stemming from maintenance and upgrade revenues and
our customer support department has grown and the need to defer revenue over the
life of the customer support contract was not done. We charge the customer
separately for the maintenance and upgrade element of our fees. Therefore, we
have evaluated what portion of the maintenance/upgrade revenue should be
recognized over the straight-line basis and have deferred the unearned portion
which is recognized as an increase in deferred revenue in the amount of $258,298
and a decrease to revenue in the amount of $239,031, noting a difference for
foreign currency translation.

In response to our oversight we have established new policies to track the
revenue generated from maintenance and upgrade revenue. Additionally, we have
described below our significant accounting policies regarding this revenue
stream in both the financial statements and the MD&A potion of our filings. They
are as follows:
<PAGE>

The Company has adopted Statement of Position (SOP) 97-2, Software Revenue
Recognition, as well as SOP 98-9, Modification of SOP 97-2, Software Revenue
Recognition with Respect to Certain Transactions. The SOPs generally require
revenue earned on software arrangements involving multiple elements to be
allocated to each element based on the relative fair market values of each of
the elements. The fair value of an element must be based on vendor-specific
objective evidence (VSOE) of fair value. Software license revenue allocated to a
software product is recognized upon delivery of the product, or deferred and
recognized in future periods to the extent that an arrangement includes one or
more elements that are to be delivered at a future date and for which VSOE has
not been established. Maintenance and support revenue is recognized ratably over
the maintenance term. First-year maintenance typically is sold with the related
software license and renewed on an annual basis thereafter. Estimated fair
values of ongoing maintenance and support obligations are based on separate
sales of renewals to other customers or upon renewal rates quoted in the
contracts. For such arrangements with multiple obligations, the Company
allocates revenue to each component of the arrangement based on the estimated
fair value of the undelivered elements. Fair value of services, such as
consulting or training, is based upon separate sales of these services. The
Company at times may enter into multiple-customer contracts in which the Company
allocates revenue based on the number of specified users at each customer, and
recognizes revenue upon customer acceptance and satisfying the other applicable
conditions of the above described accounting policy.

We have considered EITF 00-21, Accounting for Revenue Arrangements With Multiple
Deliverables, which identifies when separation of sales arrangements for revenue
recognition purposes is appropriate. We have determined that a portion of our
revenue generated from maintenance and upgrades should be recognized over the
period of the individual contracts and not at the time of initial charge to the
customer. As stated above, we charge and track the maintenance/upgrade revenue
separately and have based our fees on those of other vendor's in our industry.

We have also considered Item 5-03(b) of Regulation S-X. It was only during the
year ended October 31, 2004 that our revenue generated from services
(maintenance/upgrade, consulting and technical support) exceeded 10% of the
total revenue. We have reclassified the revenue generated from those services in
the restated financial statements in accordance with Item 5-03(b) of Regulation
S-X.

Comment 5 - Non-consolidation of forgiveness of loan to Superclick Networks,
Inc. from Superclick, Inc.

Please refer to answer under item 3.

Comment 6 - Note M Restatement.
<PAGE>

We have revised our statement that "the SEC determined the acquisition of
Superclick Networks, Inc. was a reverse merger" to "In March, 2005 we concluded
that the acquisition of Superclick Networks, Inc. was a reverse merger or
recapitalization."

Comment 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 that they are effective.

We have concluded that certain of our internal controls were deficient as of the
year ended October 31, 2004 and certain materials weakness existed. We have also
included a discussion on steps the Company is taking to address those issues.

In particular,

(a) Evaluation of disclosure controls and procedures

As required by Rule 13a-15(b) under the Exchange Act, we conducted an
evaluation, under the supervision and participation of our management, including
the Company's Acting President and Acting Chief Financial Officer (who is the
principal accounting officer), both of whom were appointed in the interim
capacity in April, 2005, to evaluate the effectiveness of the Company's
disclosure controls and procedures as of the end of the period covered by this
report. Based on the foregoing, it was determined that our internal controls
over the revenue recognition of our accounting staff with respect to revenue
recognition in conjunction with service contract revenue was deficient.
Specifically, the deferral and amortization over the life of a contract was not
performed. In addition, we identified that certain issued and outstanding
options that permit "cashless exercise" should be subject to variable plan
accounting treatment under applicable accounting standards. Accordingly,
previously unrecognized compensation expense needed to be recognized as
compensation expense in our previously issued financial statements under the
Financial Accounting Standards Board's Interpretation 44, "Accounting for
Certain Transactions involving Stock Compensation - an interpretation of APB
Opinion No. 25" (Issue Date 3/00).See Note H to Notes to Financial Statements
commencing at Page F-24 of this report.

Our interim President and Principal Financial Officer have also identified
certain additional deficiencies, including a lack of an appropriately rigorous
system of policies and procedures for the internal review of financial reports,
including inadequate staffing, training and expertise and improper accounting
procedures for grants with "cashless exercise" provisions per Financial
Accounting Standards Board's Interpretation 44, "Accounting for Certain
Transactions involving Stock Compensation - an interpretation of APB Opinion No.
25". Our independent registered public accountants, Bedinger and Company have
indicated that they considered these deficiencies to be material weaknesses as
that term is defined under standards established by the Public Company
Accounting Oversight Board (United States). These material weaknesses included
the following: the ineffectiveness of a rule compliance checking procedure for
SEC filings.
<PAGE>

In light of the need for a restatement and the material weaknesses in our
internal controls, commencing in the third quarter of our 2005 fiscal year, we
are beginning to undertake a review of our disclosure, financial information and
internal controls and procedures. This review will include our efforts by our
management and directors, as well as the use of additional outside resources. We
are committed to addressing our control environment and reporting procedures.

Our management, including our interim Chief Executive Officer and Interim
Principal Financial Officer, does not expect that disclosure controls or
internal controls over financial reporting will prevent all errors or all
instances of fraud, even as the same are improved to address any deficiencies.
The design of any system of controls is based in part upon certain assumptions
about the likelihood of future events, and there can be no assurance that any
design will succeed in achieving its stated goals under all potential future
conditions. A control system, no matter how well designed and operated, can
provide only reasonable, not absolute, assurance that the control system's
objectives will be met. Over time, controls may become inadequate because of
changes in conditions or deterioration in the degree of compliance with policies
and procedures. Further, the design of a control system must reflect the fact
that there are resource constraints, and the benefits of controls must be
considered relative to their costs. Because of the inherent limitation of a
cost-effective control system, misstatements due to error and fraud may occur
and not be detected.

(b) Changes in internal controls

Subsequent to the date of the evaluation referenced above, the Company
recognized certain material weaknesses in its internal controls and procedures:

o        Lack of appropriately rigorous system of policies and procedures for
         the internal review of financial reports, including inadequate
         staffing, training and expertise.
o        Improper accounting procedures for grants with "cashless" exercise
         provisions for Financial Accounting Standards Board's Interpretation
         44, "Accounting for Certain Transactions involving Stock Compensation -
         an interpretation of APB Opinion No. 25".

We have rescinded our cashless exercise provision for all outstanding option
grants pursuant to a resolution adopted by the Board of Directors of the Company
on June 1, 2005. Thus we expect that variable accounting will no longer be
required after the end of the Company's fiscal quarter ended July 31, 2005.

Comment 8 - Please amend your certifications to conform exactly to the form
provided for in the revised rules release effective August 14, 2003....Also,
revise the certifications that were filed as exhibits to your subsequent Form
10-QSB/A.
<PAGE>

We have amended our certifications to conform to the form provided in the
revised rules release effective August 14, 2003. In exhibits 31.1 and 31.2 we
have restated the "Rule 13(a)-14(a)/15d-14(a)" to "Rule 13a-15(e)/15d-15(e)."

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

Comment 9 - Revise to Comply with the above comments to the extent applicable.

We have made amendments to the Form 10-QSB/A to the Financial Statements to
reflect the deferral of maintenance and upgrade revenue, the difference for
compensation expense due to the implementation of variable pricing for stock
options, and elimination of the gain on loan forgiveness; to Part I, Item 2
(MD&A) to (a) update the results of the Company's operations to reflect the
restated financial statements, (b) to revise the management's discussion on the
Company's financial condition and to discuss its financing activities as well as
its "going concern" status and to Part 1, Item 3 (Controls and Procedures) to
note that certain of our internal controls were deficient as of the Quarter
ended January 31, 2005 and certain material weaknesses existed as well,
including a discussion on steps the Company is taking to address those issues
(see also Comment 8 above). In addition, we have amended the signature page and
Certifications to reflect a change in reference from "Rules 13a -14(c) and 15d -
14 (c)" to "Rules 13a - 15(e) and 15d - 15(e)" which became ef