SecProbe.io

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         August 29, 2005

   Mail Stop 4561

Amit Sankhala
President and Chief Executive Officer
CTT International Distributors Inc.
1145 West 7th Avenue
Vancouver, BC V6H 1B5 Canada

	Re:	CTT International Distributors Inc.
		Amendment No. 1 to Form SB-2
		Filed on August 8, 2005
		File No. 333-124286

		Form 10-QSB
      Filed on August 15, 2005
      File No. 000-30919

Dear Mr. Sankhala:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your document 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

      All page numbers refer to the marked courtesy copy that you
provided to us.

Form SB-2

General Comments

1. We note from page 51 that you sold 700,000 shares for $70,000
on
July 13, 2005 in an unregistered offering to five people.  We
further
note that all of the participants in the offering are registering
their shares for resale as a part of this public offering.  We
have
the following comments:

* Please tell us in more detail how this offering is exempt from
registration under Section 4(2) and Reg. S.  As part of this,
please
tell us why your current registration does not constitute a
"general
solicitation" that may have the effect of undermining your claimed
exemption under Section 4(2).

* In addition, please tell us why the private placement should not
be
integrated with the public offering.  Your analysis should be
thorough and detailed and contain references to applicable
Commission
rules, including Rule 502 of Regulation D.  In addition, please
advise us as to why you believe that these shares are eligible to
be
resold publicly as part of this registration statement.  In other
words, if they were offered privately, please advise us as to why
you
believe the private offering was concluded.

* Supplementally, please provide us with copies of all
documentation
and correspondence generated or used in connection with the
private
placement, including information presented or provided to your
investors.

2. We note that your subsidiary privately placed 455,001 shares in
December 2004 at $0.10 per share.  Mr. Sankhala purchased only one
of
these shares and was not, apparently, a significant holder of
stock
in your subsidiary.  We further note that these shares were
exchanged
one-for-one with stock in Slabsdirect.com as a part of the reverse
acquisition in December 2004.  Finally, we note from page 27 that
the
principal shareholder of Slabsdirect.com, Steve Bruk, sold
8,634,617
shares to Mr. Sankhala for $25,000 in a private transaction.  This
amounts to roughly $0.0029 per share, a significant discount to
the
price paid by holders of stock in your subsidiary and the source
of
significant dilution to them.  Please tell us whether you provided
your subsidiary investors with information related to the Bruk-
Sankhala transaction prior to their decision to move ahead with
the
merger.  If so, please provide us with copies of this information.
Also, in light of the fact that Mr. Bruk was a principal
shareholder
of Slabsdirect.com, please tell us why we should not view the
apparent discounted stock price as compensation for Mr. Sankhala.

3. Please update your registration statement to include your June
30,
2005 financial statements in accordance with Rule 3-12 of
Regulation
S-X.

Outside Front Cover of Prospectus

4. We note your response to prior comment 6 and we re-issue the
comment.  Please tell us why your intention to change the offering
price of your common stock would not constitute a delayed offering
pursuant to Rule 415(a)(1)(x) which can only be conducted by a
company that is eligible to utilize Form S-3 for the offering.
Alternatively, please revise your disclosure to make clear that
the
primary and secondary components of the proposed offering will
both
be conducted at a fixed price of $0.10 until your shares are
approved
for trading on the OTC Bulletin Board.

Summary of Offering, page 5

Risk Factors, page 6

5. Please add a risk factor regarding the fact that the proposed
primary offering is a "best efforts" offering with no stated
minimum
and that, as a result, investor funds will not be placed in an
escrow
account pending the attainment of a certain amount of proceeds or
other event.

CTT does not have sufficient..., page 7

6. Please be more specific in your disclosure.  We note from page
37
that your offering, even if fully subscribed, would still leave
you
$113,600 short of funding your plan.  To the extent you intend to
rely on additional stock offerings to make up the shortfall,
please
discuss the associated risk of dilution and pressure on your share
price.

Failure to successfully compete..., page 8

7. Please disclose that there are few barriers to entry in your
business.  Also, please make it clear that there is already
significant competition in your market, as suggested by your
disclosure on page 33.

CTT`s sole officer and director..., page 8

8. Please remove the cross reference from this risk factor and
include the material information from page 24.

CTT has no independent board member..., page 9

9. Please describe with more specificity the conflicts related to
the
enforcement of your code of ethics.  In making your revisions,
please
eliminate the cross reference to your exhibits, identify any
material
provisions that may be undermined as a result of not having an
independent board, and explain how this might hurt the interests
of
your investors.

CTT may be subject to liability..., page 10

10. The second paragraph of this risk factor appears to be based
on a
number of factual assumptions, including the entry into "strategic
alliances" and sales in Japan.  Since the risk itself appears to
focus on the potential assessment for past sales, please omit
disclosure regarding sales that have not yet occurred.

Security of online transactions..., page 11

11. Please disclose whether you retain credit card information.

If and when CTT`s shares of common..., page 12

12. Please disclose how many shares will be outstanding and how
many
shares will be freely tradable following this offering.

Use of Proceeds, page 14

13. We note from page 37 that you are not raising sufficient funds
to
cover your anticipated costs during the next 12 months.  Please
disclose this here.

Plan of Distribution, page 18

14. Please revise your description of Reg. M on page 23 to make
clear
precisely what activities are prohibited and why (i.e., how these
activities could lead to price manipulation).  Also, please define
technical terms like "stabilization," "syndicated short positions"
and "penalty bids."  Finally, please explain when the restricted
period would be one day and when it would be five days.

Management, page 24

Background of sole officer and director, page 24

15. We note from your response to prior comment 19 that Tiger
Ventures "shut down operations" in July.  Please revise your
description of Mr. Sankhala to make clear which, if any, of his
past
ventures are still operating and disclose whether Tiger Ventures
(or
any of the others) filed for bankruptcy protection.  See Item
401(d)
of Regulation S-B.  Also, please disclose when Mr. Sankhala formed
Dynamic Tours, Tiger Ventures and Tiger Resorts, and where each of
these entities is based.

Certain Relationships and Related Transactions, page 27

Transactions with Promoters, page 27

16. Please tell us why you have not described in this section all
transactions involving Mr. Sankhala, including the loans described
in
notes 4 and 5 to your financials.  Refer to Item 404(d) of Reg. S-
B.

Description of Securities, page 28

17. We note your statement that under Section 3 of Article V of
your
bylaws transfer restrictions apply only if your are not a
reporting
company.  At the same time, you state that under Article V(c)(3)
of
your articles and Section 2 of Article V of your bylaws your
directors may in fact restrict transfers.  Please clarify the
meaning
and interrelationship of these provisions.  If transfer
restrictions
currently apply, please make this clear and include appropriate
disclosure in your risk factors section.  Also, please clarify
what
you mean where your state that "normally" your board would only
restrict transfers "in compliance" with Rule 144.

Description of Business, page 29

18. Please discuss any reliance on foreign markets for a material
amount of sales.  In addition, please quantify the portion of your
sales that have come from the United States, Canada and the UK.

Products and Services, page 30

Direct Business, page 30

19. We note that you rely on three suppliers in Taiwan and China
for
your merchandise for direct (as opposed to fulfillment) sales to
consumers and wholesalers.  Please explain how this comports with
disclosure on page 32 that you have only one supplier, LTP Tech,
who
apparently supplies only Chinese products.  Finally, please
clarify
the difference between suppliers and your three manufacturers and
two
liquidators also mentioned on page 32.  Are these manufacturers
and
liquidators related only to your direct business?

Market, page 32

20. We note your response to prior comment 60.  However, given the
large number of competitors identified by you on page 33, we
continue
to question your support for the assertion that this market is
characterized by only a "limited number of competitors."  Please
provide additional support or remove this disclosure.

Technology and Intellectual Property, page 32

21. We note that you utilize contractual agreements with
employees,
customers, suppliers and affiliates to protect your proprietary
information.  Please revise to avoid any suggestion that you have
employees.  Also, please provide us with copies of all agreements
with customers, suppliers and affiliates showing the terms to
which
you refer in this disclosure.  Finally, please clarify what
proprietary technologies and third-party licenses you are relying
on.

Competition, page 33

22. In order to avoid investor confusion regarding the extent to
which you compete with any of the companies listed, please remove
the
names of all companies from this section.  Your description of the
lines of business against which you compete is sufficient.  Also,
please balance your description, on page 34, of competitive
advantages with an equally detailed discussion of why
manufacturers
may not want to work with you, including your only officer`s lack
of
experience in this area, your limited operating history and
resources, your limited protections against computer fraud and
theft
of personal information, your lack of a physical presence and
other
factors.

MD&A, page 36

23. We note your response to prior comment 44.  Please tell us why
your expenses for 2004 did not change with the removal of a $5,000
payment to an entity affiliated with Mr. Sankhala.  Also, please
confirm that no entity affiliated with Mr. Sankhala received such
a
payment.  In this regard, we note from page 38 that you incurred a
$5,000 Internet marketing expense in 2004.

24. We note from page 37 your belief that your software
development
costs of $2,500 are non-recurring.  Please provide us with
additional
support.  In responding, please consider: (1) that you intend to
spend more than $110,000 of the proceeds of this offering on
development projects related to your website and; (2) from page 8,
that your success depends upon your ability to develop new
technology
services quickly.

Results of operations, page 37

25. We note that you have provided unit sales and margin
information
for 2004.  Please provide comparable information for the first
quarter of 2005 and discuss any evident trends.

26. Please explain in detail why your average monthly revenue
dropped
to $333 in the quarter ending March 31, 2005, from roughly $4,400
in
2004.  Also, please explain how you experienced negative gross
margin
in the first quarter, given your disclosure that your cost of sale
consists "solely" of inventory cost.  Please disclose whether you
sold products for less than you paid for them and, if so, why.

27. Please explain why "rent" in the first quarter came out to
$678
per month while rent in 2004 came out only to roughly $354.  Also,
for both periods, please explain what your "consulting" fees
consisted of and to whom they were paid.

28. We note from page 30 that direct consumer sales have comprised
20% of your business to date, while wholesale purchases
(presumably
both direct and fulfillment-based) have comprised 80%.  Please
explain how this comports with disclosure on page 39 that direct
sales comprise 25% of your business.  Also where relevant, please
clarify whether you make any "fulfillment" sales to consumers and,
if
so, explain where they show up in the mix described above.
Finally,
please provide the breakdown of sales in each period to clarify
the
discrepancy identified above and discuss any evident trends.

29. We note your response to the first bullet point of prior
comment
75.  This suggests that you did at some point verify payment prior
to
shipping.  If so, please disclose when, explain why you stopped
this
practice, consider whether additional risk factor disclosure
(including risk related to credit concentration) may be warranted
and
disclose the identity of material obligees and the terms of
payment.
Please disclose how much time passes between shipping the product
and
verifying payment and your average days sales outstanding in each
period.  Also, assuming you did verify payment prior to shipment
at
some point in 2004, please tell us how you accumulated accounts
receivable in the amount of $22,829 by the end of that period.

Current capital resources and liquidity, page 39

30. Please revise your discussion of cash flow from operating
activities to discuss the underlying drivers impacting the changes
in
working capital. Simply identifying items that are apparent from
the
statement of cash flows does not provide a sufficient basis to
analyze your cash flow from operating activities.  Refer to
Release
33-8350.

31. For the sake of clarify, please discuss separately cash flows
from investment and financing activities in each period.

32. We note that your cash decreased from $28,214 on December 31,
2004 to $11,259 on March 31, 2005.  This suggests cash usage (or
burn) of nearly $6,000 per month (as opposed to the $3,000
mentioned
on pages 7 and 40).  In light of these results, please disclose
the
basis of your statement here that you have four months of cash
remaining.

33. We note that you have received "verbal extensions" on your
accounts payable.  Please identify the suppliers who have provided
you with such extensions and the amounts in questions.  Also, if
true, please disclose that these "verbal extensions" do not amount
to
enforceable agreements and that your creditors could seek payment
at
any time.  In that regard, please disclose which of these payments
are overdue and discuss cash flow risk (both here and in your risk
factors) related to an acceleration of these payables or the
demand
notes described in notes 4 and 5 to your first quarter financials.

Plan of Operation

Phase 4 - Corporate Development, page 42

3