SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>slabsdirectletter.txt
<DESCRIPTION>COMMENT LETTER ON ITEM 4 FORM 8-K; SENT 8/31/04; C. LUCKEY
<TEXT>

					August 31, 2004

Mail Stop 0409

VIA U.S. MAIL AND FAX (604) 682-5564

Steven Bruk
Chief Executive Officer
Slabsdirect.com, Inc.
1145 West 7th Avenue
Vancouver, British Columbia  V6H 1B5

Re:	Form 8-K Filed August 30, 2004

Dear Mr. Bruk:

We have reviewed your filings and have the following comments.  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.

	Please understand that the purpose of our review process is to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other aspect
of our review.  Feel free to call me at the telephone number listed
at the end of this letter.

1. Item 304(a)(1)(ii) of Regulation S-B requires a statement whether
the accountants` report on the financial statements for either of the
past two years contained an adverse opinion or a disclaimer of
opinion or was qualified or modified as to uncertainty, audit scope
or accounting principles; and a description of the nature of each
such adverse opinion, disclaimer of opinion, modification or
qualification.  This would include disclosure of uncertainty
regarding the ability to continue as a going concern as referenced in
the accountant`s report for the fiscal years ended December 31, 2001
and 2000.

2. We note that subsequent to filing the Form 10-QSB for the
quarterly period ended March 31, 2002 on May 14, 2002, you did not
comply with your periodic reporting requirements until August 2004.
Please supplementally advise us why you were not in compliance with
your reporting requirements for the period from May 2002 through
August 2004.  In addition, tell us how you were able to provide true
and accurate Item 8A and Item 3 disclosures regarding Controls and
Procedures in your Forms 10-KSB and 10-QSB respectively as filed on
August 27, 2004.  Inability to comply with your reporting
requirements may indicate you lack the necessary disclosure controls
and procedures as well as internal controls.  Tell us what changes
you have made or procedures implemented to correct these
deficiencies.

3. To the extent that you make changes to the Form 8-K to comply with
our comments, please obtain and file an updated Exhibit 16 letter
from the former accountants stating whether the accountant agrees
with the statements made in your revised Form 8-K.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require.  Since the
company and its management are in possession of all facts relating to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement has
access to all information you provide to the staff of the Division of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

Please provide the supplemental information requested above within 10
business days from the date of this letter.  The supplemental
information should be filed as correspondence on EDGAR.  The
amendment requested above should be filed as promptly as possible and
should be reviewed by the newly engaged accountants before filing
with the Commission.

You may reach me at (202) 942-1975 with any questions.

						Sincerely,

						Cicely D. Luckey
						Senior Staff Accountant

Slabsdirect.com, Inc.
August 31, 2004

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