SecProbe.io

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                        COLLECTIBLE CONCEPTS GROUP, INC.
                              1600 LOWER STATE ROAD
                         DOYLESTOWN, PENNSYLVANIA 18901

================================================================================

October 20, 2005

VIA EDGAR AND FEDERAL EXPRESS
-----------------------------

Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549

         Attn:    H. Christopher Owings, Assistant Director
                  Division of Corporation Finance

                  Ellie Quarles, Esq.
                  Scott Anderegg, Esq.

         Re:      Collectible Concepts Group, Inc.
                  Form 10-KSB for the Fiscal Year Ended February 28, 2005
                  Form 10-QSB for the Fiscal Quarter Ended May 31, 2005
                  Schedule 14C filed September 6, 2005
                  File No. 000-30703

Ladies and Gentlemen:

      The following responses address the comments of the reviewing Staff of the
Commission  as set forth in a  comment  letter  dated  September  14,  2005 (the
"Comment Letter") relating to the Preliminary  Information Statement on Schedule
14C (the  "Information  Statement") of  Collectible  Concepts  Group,  Inc. (the
"Company").  The answers set forth herein refer to each of the Staffs'  comments
by number.

      We are  filing  herewith  Amendment  No.  2 to the  Company's  Information
Statement.

Form 10-KSB for the Fiscal Year Ended February 28, 2005
-------------------------------------------------------

Description of Business, page 2
-------------------------------

1.    Please revise your disclosure to identify your major (89%)  customer.  See
      Item 101(b)(6) of Regulation S-B.

<PAGE>

Securities and Exchange Commission
October 20, 2005
Page 2 of 7

      Response
      --------

      Pursuant  to  Item  101(b)(6)  of  Regulation  S-B,  we have  revised  our
      disclosure to indicate that CLP Group is a major  customer,  who accounted
      for 89% of our revenues during our last fiscal year. We have also included
      a risk factor on our dependence on our major customer.

Market for Common Equity and Related Stockholder Matters, page 7
----------------------------------------------------------------

2.    Please provide the disclosure required by Item 201(d) of Regulation S-B.

      Response
      --------

      We have revised our  disclosure  to indicate that we do not have any stock
      option  plans as of  February  28,  2005,  as  required  by Item 201(d) of
      Regulation S-B.

Recent Sales of Unregistered Securities, page 7
-----------------------------------------------

3.    We note your disclosure of recent sales of unregistered securities. Please
      furnish the complete disclosure required by Item 701 of Regulation S-B. In
      this regard, please indicate the section of the Securities Act or the rule
      of the Commission under which exemption from  registration was claimed and
      state  briefly  the facts  relied  upon to make the  exemption  available.
      Please  provide us with your legal  analysis as to why these  issuances of
      securities  should not be integrated  and should not have been  registered
      under the Securities Act.

      Response
      --------

      We have revised our disclosure to include all information required by Item
      701 of  Regulation  S-B. We believe  that the  issuances  of  unregistered
      securities  should  not be  integrated  and did not need to be  registered
      under  the  Securities  Act of 1933.  The  reasons  we  believe  there The
      issuance of shares were to a limited  number of  accredited  investors who
      all had an  ongoing  relationship  with us.  The  number of shares  issued
      represented  less than 10% of our total issued and  outstanding  shares of
      common  stock.  In  addition,  we directly  discussed  the issuance of the
      shares  with the  receipient,  and there  were no  mechanisms  of a public
      offering.  In addition,  applying the factors from the five-part  test set
      forth in  Securities  Act Release  33-4552  (November 6, 1962),  we do not
      believe  there  is a  basis  for  integration.  Looking  at the  two  most
      important  factors,  as set forth in  Sonnenblick,  Parker & Selvers,  the
      financings  did not consitute a single plan of financing and the offerings
      were not for the same general  purpose.  Even if the offerings  were to be
      integrated,  which we do not believe they should, the integrated  offering
      would be exempt  from  registration  pursuant  to  exemptions  provided by
      Section 4(2) of the  Securities  Act and Rule 506 of  Regulation  D.

<PAGE>

Securities and Exchange Commission
October 20, 2005
Page 3 of 7

4.    We note  that you  disclose  that you do not have a  sufficient  number of
      authorized  shares  available to issue to convertible debt holders if they
      all  converted  their  shares  to common  stock.  Please  provide  greater
      disclosure as to how this miscalculation  occurred and the steps necessary
      to authorize additional shares.

      Response
      --------

      We have expanded our disclosure under liquidity and capital resources,  in
      the management's  discussion and analysis or plan or operations section to
      discuss why we do not have enough authorized but unissued shares of common
      stock to be  issued  upon  conversion  of the  convertible  debt.  We have
      further  disclosed the steps necessary to authorized  additional shares of
      common stock.

5.    Please revise the disclosure of your sales of  unregistered  securities in
      this section to ensure that it is  internally  consistent  and  consistent
      with the disclosure under Liquidity and Capital Resources. You also should
      include the issuances of convertible notes in this disclosure.

      Response
      --------

      We did not issue any  convertible  notes  during  the three  months  ended
      February  28,  2005,  therefore,  we do not provide any  disclosure  under
      Recent Sales of Unregistered Securities. In addition, we have reviewed our
      disclosures  under Recent Sales of  Unregistered  Securities and Liquidity
      and  Capital   Resources  and  do  not  believe  that  the  disclosure  is
      inconsistent. If the Staff has any particular disclosures it would like us
      to clarify, we would be happy to do so.

Management's Discussion and Analysis or Plan of Operation, page 9
-----------------------------------------------------------------

6.    If material,  please file your agreement with Joe Theismann as an exhibit.
      See Item 601(b)(10) of Regulation S-B.

      Response
      --------

      We have filed the agreement with Joe Theismann as an exhibit.

7.    Please revise your  disclosure to identify the party to whom you sold 2.5%
      of your future revenues from your NFL, NBA and possible MLB licenses.

      Response
      --------

      We have revised our  disclosure to indicate that we sold the 2.5% interest
      to Alizay Consultant Limited.

<PAGE>

Securities and Exchange Commission
October 20, 2005
Page 4 of 7

Liquidity and Capital Resources, page 11
----------------------------------------

8.    Please include in your  disclosure the impact on liquidity of the terms of
      your Securities  Purchase  Agreement with AJW Offshore Ltd., AJW Qualified
      Partners,  LLC, JW Partners,  LLC and Millennium Capital Partners II, LLC.
      Please add disclosure  that addresses the  possibility  that the number of
      shares  you  issue in  connection  with a draw down  under the  Securities
      Purchase  Agreement  will be based upon a discount to the then  prevailing
      market  price and,  as a result,  the lower the stock price at the time of
      the draw down, the more common shares the stockholder will receive. To the
      extent that these investors  receive and then sell their common stock, the
      common  stock  price  may  decrease  due to the  additional  shares is the
      market.  This could allow these  investors to receive even greater amounts
      of common stock, the sales of which would further depress the stock price.

      Response
      --------

      We have revised our disclosure to provide for risk factors  concerning our
      financing  agreements  that  addresses and contains all of the  disclosure
      requested.

9.    We note the chart you included on page 7 of your  Schedule 14C  concerning
      the amount of shares you would be required to issue under the terms of the
      Securities  Purchase  agreement based on market prices of 25%, 50% and 75%
      below the market  price of  $0.0016.  Please  expand  your  disclosure  to
      provide a similar  chart in your  discussion  of the  Securities  Purchase
      Agreement.

      Response
      --------

      As noted  above,  we have revised our  disclosure  to provide risk factors
      that includes the requested chart.

10.   Please  expand  your  discussion  to  disclose  your  liquidity  on both a
      short-term and long-term  basis and your ability to fund your  operations.
      See Item 303 of Regulation S-B.

      Response
      --------

      We have  expanded  our  disclosure  to  discuss  our  liquidity  on both a
      short-term and long-term basis and our ability to fund our operations,  as
      required by Item 303 of Regulation S-B.

11.   Please expand your  disclosure to include your default of the  requirement
      that you effectuate a registration statement within 150 days from the sale
      of convertible securities.

<PAGE>

Securities and Exchange Commission
October 20, 2005
Page 5 of 7

      Response
      --------

      We have revised our  disclosure to state that one of the events of default
      was our requirement to have an effective registration statement within 150
      days from the sale of the convertible securities.

12.   Please  disclose  the amount of the unpaid  royalty  payments  due on your
      sports licenses.

      Response
      --------

      We have revised our  disclosure  to indicate the amount of our accrued but
      unpaid royalty payments due on our sports licenses.

Controls and Procedures, page 18
--------------------------------

13.   Please expand your  discussion  to disclose  whether you believe the steps
      you have taken will correct your  material  deficiencies  and  significant
      weakness and when you expect the changes to be effective.

      Response
      --------

      Our  disclosure  already  indicates that we believe that the steps we have
      taken will  correct our  material  deficiencies  and  weaknesses.  We have
      expanded our  disclosure to indicate that we believe that the changes will
      be effective before the end of the November 30, 2005 quarter.

Exhibits, page 24
-----------------

14    We note your  discussion in your  Management's  Discussion and Analysis or
      Plan of  Operation  of several  licensing  agreements.  For  example,  you
      discuss  entering into licensing  agreements  with DPI, the NFL, the Arena
      Football  League  and the NBA.  Please  file  these  agreements.  See Item
      601(b)(10) of Regulation S-B.

      Response
      --------

      We have filed the agreements with the National  Football League,  National
      Basketball Association and the Arena Football League as exhibits.

<PAGE>

Securities and Exchange Commission
October 20, 2005
Page 6 of 7

Form 10-QSB for the Fiscal Quarter Ended May 31, 2005
-----------------------------------------------------

Notes to Condensed Consolidated Financial Statements as of May 31, 2005, page 7
-------------------------------------------------------------------------------

Note 6, page 14
---------------

15.   We note that you  purchased  15,000,000  shares of your common  stock from
      your Chief  Executive  Officer and his wife for $30,000.  Please advise us
      whether the  purchases  were on comparable  terms to recent  issuances and
      provide similar disclosure in future reports.

      Response
      --------

      The purchase of 15 million shares of common stock from our Chief Executive
      Officer  and his wife  for  $30,000  was on  comparable  terms  to  recent
      issuances. We will provide disclosure to this effect in future reports.

Controls and Procedures, page 24
--------------------------------

16.   Please update your discussion to disclose your progress in correcting your
      material  deficiencies  and weaknesses  and when you anticipate  that they
      will be corrected.

      Response
      --------

      We have  revised  our  disclosure  to provide  further  disclosure  on our
      progress  and  when we  anticipate  that  our  material  deficiencies  and
      weaknesses will be corrected.

Change in Securities and Use of Proceeds, page 25
-------------------------------------------------

17.   Please identify the person(s) or the class of person(s) that purchased the
      securities issued. These securities appear to have been issued in exchange
      for services  rendered.  Please state the value of the services  rendered.
      Also,   please  ensure  that  this  disclosure  is  consistent  with  your
      disclosure  of  the  sales  of  securities  found  in  your   Management's
      Discussion and Analysis of Financial Condition and Results of Operations.

      Response
      --------

      We have revised our disclosure to indicate that the shares of common stock
      were issued to Richard  Epstein and the services  rendered  were valued at
      $30,000.  We have also ensured that our disclosure is consistent  with the
      disclosure in our MD&A section.

<PAGE>

Securities and Exchange Commission
October 20, 2005
Page 7 of 7

Schedule 14C filed September 6, 2005
------------------------------------

Amendment to the Articles of Incorporation, page 4
--------------------------------------------------

18.   In the first  paragraph,  you  indicate  that you propose to increase  the
      number of  authorized  shares to  10,000,000,000,  yet,  in the  notice to
      stockholders,  you  indicate  that this amount is  15,000,000,000.  Please
      reconcile these amounts.

      Response
      --------

      We have revised our  disclosure to indicate that the proposed  increase is
      to 15 billion shares, not 10 billion.

19.   In the first  paragraph  of this  disclosure  you state that a majority of
      stockholders   had  approved  the   amendment  to  your   Certificate   of
      Incorporation.  It  appears  from the  context  that it was the board that
      approved the amendment. Please revise.

      Response
      --------

      Our board of directors  has approved the amendment to our  Certificate  of
      Incorporation as well as a majority of our  stockholders.  We have revised
      our disclosure to indicate that both our board of directors and a majority
      of our  shareholders  have  approved the amendment to our  Certificate  of
      Incorporation.

2005 Incentive Stock Option Plan, page 15
-----------------------------------------

20.   Please provide all of the  information  required by Item 1 of Schedule 14C
      and Item 10 of  Schedule  14A.  Please  file the stock  option  plan as an
      appendix to the  information  statement.  See  Instruction 3 to Item 10 of
      Schedule 14A.

      Response
      --------

      We  have  filed  the  2005  Incentive  Stock  Plan  as  exhibit  B to  the
      information statement.

      We trust that the foregoing  appropriately  addresses the issues raised by
your recent  Letter of Comment.  Thank you in advance for your prompt review and
assistance.

                                        Very