SecProbe.io

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August 15, 2005

Mr.Larry Spirgel
Assistant Director
Division of Corporate Finance
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Mail Stop 0407
Washington DC 20549

RE: Superclick, Inc. Comment Letter dated July 27, 2005
Form 10-KSB for the fiscal year ended October 31, 2005; Forms 10-QSB for the
Fiscal Quarters Ended January 31, 2005 and April 30, 2005

File No. 333-31238

Dear Mr. Spirgel,

In response to your comments in your letter dated July 27, 2005 regarding your
review of Form 10-KSB for the fiscal year ended October 31, 2005; Forms 10-QSB
for the Fiscal Quarters Ended January 31, 2005 and April 30, 2005, and to the
"adequacy and accuracy" of the disclosures therein, we have (a) filed a Form 8-K
in accordance with Item 4.02 of the Securities Exchange Act of 1934; (b) made
amendments to Item 8A in our 10-KSB for the fiscal year ended October 31, 2004
and to Part 1 Item 3 on our Forms 10-QSB for the periods ended January 31, 2005
and April 30, 2005; (c) made amendments in the aforementioned filings to conform
with Item 308(c) of Regulation S-B; and (d) amended our Certifications on the
aforementioned filings to conform exactly to the form provided for in the
revised rules release effective August 14, 2003. In light of the fact that each
of the Forms referred to herein have required amended Certifications, we have
re-filed each of them in their entirety.

In response to Comment 5, we have amended and restated our financial statements
for the fiscal quarters ended January 31 and April 30, 2004 included in the
filed Form 10-QSB/A reports for the fiscal quarters ended January 31, 2005 and
April 30, 2005.

In response to Comment 6, we have amended our Rule 13a-14(a) Certifications in
the Form 10-QSB/A reports for the fiscal quarters ended January 31, 2005 and
April 30, 2005 to conform exactly to the form provided for in the revised rules
release effective August 14, 2003 and pursuant to Item 601(b)(31) of Regulation
S-B and Securities Act Release No. 33-8238. Since we have filed the Rule
13a-14(a) certifications with the amendment, we have included the referenced
Form 10-QSB/A reports in their entirety in our amendment.

We have included with this response letter:

1)       Form 8-K, re: Item 4.02 filed with the SEC on August 10, 2005
2)       Form 10-QSB/A Amendment No. 3 for the Quarter ended January 31, 2005,
         originally filed with the SEC on March 16, 2005 and most recently
         (pursuant to the SEC's July 27,2005 comment letter) amended and filed
         with the SEC on August 15, 2005

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3)    Form 10-QSB/A Amendment No. 3 (track changes) for the Quarter ended
      January 31, 2005 and filed on August 15, 2005.

4)    Form 10-QSB/A Amendment No. 1 for the Quarter ended April 30, 2005,
      originally filed with the SEC on July 17, 2005 and most recently (pursuant
      to the SEC's July 27, 2005 comment letter) amended and filed with the SEC
      on August 15, 2005.

5)    Form 10-QSB/A Amendment No. 1 (track changes) for the Quarter ended April
      30, 2005 and filed on August 15, 2005.

6)    Form 10-KSB/A Amendment No. 3 for the Year ended October 31, 2004,
      originally filed on January 28, 2005, and most recently (pursuant to the
      SEC's July 27, 2005 comment letter) amended and filed with the SEC on
      August 15, 2005.

7)    Form 10-KSB/A Amendment No. 3 (track changes) for the Year ended October
      31, 2004 and filed on August 15, 2005.

Sincerely,

Todd M. Pitcher
Interim Chief Financial Officer
Superclick, Inc.
4275 Executive Square
Suite 215
La Jolla, CA 92037
(858) 518-1387 Phone
(858) 279-1799 Fax
tpitcher@san.rr.com
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Form 10-KSB/A for the fiscal year ended October 31, 2004

General

1.       Regarding Comment 1. We have filed a Form 8-K in accordance with Item
         4.02 of the Securities Exchange Act of 1934.

Item 8A. Controls and Procedures

2.       Regarding Comment 2. We have removed our disclosure that our disclosure
         controls can provide only "reasonable assurance" that the objectives of
         our controls systems are met.

3.       Regarding Comment 3. Pursuant to Item 308(c) of Regulation S-B, we have
         inserted the following disclosure in Item 8A:

         In accordance with Item 308 (c) of Regulation S-B, there were no
         changes in the Company's internal control reporting in connection with
         the Company's evaluation of its internal controls that occurred during
         the most recent fiscal quarter covered by this Form 10-KSB.

Form 10-QSB for the Fiscal Quarter ended January 31, 2005 and Form 10-QSB for
the Fiscal Quarter ended April 30, 2005

4.       Regarding Comment 4. We have filed a Form 8-K in accordance with Item
         4.02 of the Securities Exchange Act of 1934 disclosing the restatement
         of the Company's financial statements included on the Form 10-QSB for
         the fiscal quarter ended January 31, 2005; and

         On Forms 10-QSB for the Fiscal Quarter Ended January 31 and on the Form
         10-QSB for the Fiscal Quarter Ended April 30, 2005, we have (a) removed
         our disclosure that our disclosure controls can provide only
         "reasonable assurance" that the objectives of our controls systems are
         met from Item 2; and (b) pursuant to Item 308(c) of Regulation S-B, we
         have inserted the following disclosure in Part 1 Item 3 , Controls and
         Procedures:

         In accordance with Item 308 (c) of Regulation S-B, there were no
         changes in the Company's internal control reporting in connection with
         the Company's evaluation of its internal controls that occurred during
         the most recent fiscal quarter covered by this Form 10-QSB.

         On Form 10-QSB for the Fiscal Quarter Ended April 30, 2005, and in
         conformity with Item 308(c) of Regulation S-B, we added the additional
         disclosure that:

         However, during the most recent quarter covered by this Form 10-QSB, we
         undertook to begin evaluating upgrade software accounting systems to
         enhance our existing accounting system with the addition of new
         accounting software. We believe this will enhance our system of
         internal controls. This anticipated upgrade is being made in response
         to deficiencies in our internal controls.

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5.       Pursuant to Comment 5, we have restated our 10-QSB for both the periods
         ended January 31, 2005 and April 30 2005 to reflect the following:

         Amendment No. 3 on Form 10-QSB/A for Superclick, Inc. (the "Company")
         for the quarter ended January 31, 2005 is being filed to amend:

         [ x ] Part I, Item 1, Financial Statements (1) Update Services revenue
         to reflect that portion that should have been deferred as of the
         quarter ended January 31, 2004; (2) Update the Statement of Cash Flows
         to reflect the decrease in revenue for the portion of deferred revenue
         that was originally included in the quarter ended January 31, 2004.

         [ x ] Part I, Item 2. Management's Discussion & Analysis (1) Update
         results of Company's operations to reflect restated financial
         statements; (2) Update results of operations discussion for decrease in
         revenue for the quarter ended January 31, 2004;

         [ x ] Part I, Item 3. Controls and Procedures. Clarification of
         Company's evaluation of its internal controls in conformity with Item
         308(c) of Regulation S-B.

         [x ] Part II, Item 4. Exhibits 31 Rule 13a-14(a) Certifications to
         conform exactly to Item 601(b)(31) of Regulation S-B and Securities Act
         Release No. 33-8238.

         Amendment No. 1 on Form 10-QSB/A for Superclick, Inc. (the "Company")
         for the quarter ended April 30, 2005 is being filed to amend and
         restate items described below contained in the Company's Quarterly
         Report on Form 10-QSB for such period originally filed with the
         Securities and Exchange Commission on July 17, 2005.

         [ x ] Part I, Item 1, Financial Statements (1) Update Services revenue
         to reflect that portion that should have been deferred as of the
         quarter ended April 30, 2004; (2) Update the Statement of Cash Flows to
         reflect the decrease in revenue for the portion of deferred revenue
         that was originally included in the quarter ended April 30, 2004.

         [ x ] Part I, Item 2. Management's Discussion & Analysis (1) Update
         results of Company's operations to reflect restated financial
         statements; (2) Update results of operations discussion for decrease in
         revenue for the quarter ended April 30, 2004.

         [ x ] Part I, Item 3. Controls and Procedures. Clarification of
         Company's evaluation of its internal controls in conformity with Item
         308(c) of Regulation S-B.

         [ x ] Part II, Item 4. Exhibits 31 Rule 13a-14(a) Certifications to
         conform exactly to Item 601(b)(31) of Regulation S-B and Securities Act
         Release No. 33-8238.

6.       We have amended our 10-KSB report (No.3) for the fiscal year ended
         October 31, 2004 and our 10-QSB filings for the fiscal quarters ended
         January 31, 2005 (No.3) and April 30, 2005 (No.1) to include exhibits
         31 Rule 13a-14(a) certifications that conform exactly to the form
         provided for in the revised rules release effective August 14, 2003
         (regarding the 10-QSB filings see our response 5 above, and the Amended
         10-QSB(s) for the quarters ended January 31, 2005 and April 30, 2005
         files with the SEC on August 15, 2005).
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