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Johnstown, PA 15901

Toll Free: (800) 372-7368

Tel: (814) 361-3860

Fax: (814) 361-3861

www.eparent.com

September 22, 2005

Mr. David R. Humphrey

Branch Chief – Accountant

Securities and Exchange Commission

Washington, DC  20549-0305

RE:

EP Global Communications, Inc. (the “Company”)

Form 10-KSB/A for the Year Ended December 31, 2004

Form 10-QSB for the Quarterly Period Ended June 30, 2005

File Number 000-30797

Dear Mr. Humphrey,

EP
Global Communications, Inc. (“Company”) has received a
comment letter from the SEC under date of August 18, 2005.  As
requested in such letter, the Company herewith provides responses to
the questions raised by staff.  For convenience, the matters are
listed below, followed by the Company’s responses.

Form 10-KSB/A for the period ended December 31, 2004

General

1.

Please
revise your Form 10-KSB/A to comply with rule 12(b)-15 of the Exchange
Act, which requires the complete text of each item, as amended, to be
set forth in an amended filing.

The Company will file an amended Form 10-KSB for the year ended December 31, 2004 on approximately September 22, 2005.

Item 6 – Management Discussion and Analysis

Liquidity, page 12

2.

In
your next amendment, please expand your liquidity and going concern
disclosures to discuss the consequences should you not be able to
repay, refinance, or extend the debt that is coming due in the short
term.

As
has been discussed with Staff, the Company has not included such
disclosures in its amended Form 10-KSB/A to be filed on approximately
September 22, 2005.

Mr. David R. Humphrey, Securities and Exchange Commission, September 22, 2005     Page 2

The
Company strongly believes that the requested disclosure pertains to a
hypothetical situation that has not happened and that, in the
Company’s judgement in the context of the financial statements at
December 31, 2004, is unlikely to occur.

The
Company sees inclusion of this disclosure at this juncture (eight and
one-half months subsequent to the balance sheet date and five months
subsequent to its first filing of its annual report on Form 10-KSB) as
giving the appearance of a “back door” method of updating
disclosures for subsequent events (ie., a deterioration of the
Company’s ability to remain a going concern) that have not, in
fact, occurred.

Plainly,
in the Company’s judgement, readers of the amended Form 10-KSB
would see the inclusion of such disclosure as serving only the purpose
of laying groundwork for actions the Company was contemplating when, in
fact, that is not actually the case.

Further,
the Company has been successful in working with its vendors, creditors
and investors to continue its operations on a reasonably sound footing.
 The Company believes that inclusion of such disclosure at this
time, and the inference it would carry, would result in these parties
quickly becoming unwilling to continue to work with the Company as it
continues forward.  In effect, inclusion of the disclosure would
precipitate the very problem merely being described as a hypothetical
contingency.

The
Company is also sensitive to the real potential for harm to investors
for the same reasons articulated above.  The Company believes
that, should such disclosure be included in its Form 10-KSB, investors
may make inappropriate conclusions relative to their decision to
transact in the Company’s securities.

The
Company also finds that its views on this matter are supported by
authoritative pronouncements.  For reference, the following terms
relate to loss contingencies - probable: the future event or events are
likely to occur; reasonably possible: the chance of the future event or
events occurring is more than remote but less than likely; remote: the
chance of the future event or events occurring is slight. (FAS 5:
 Accounting for Contingencies, Issued: March 1975, paragraph 3.)

In
recognizing the problem of self-fulfilling prophecies, the Financial
Accounting Standards Board (“FASB”) itself recognized that:

“…business or economic decision makers' predictions often affect their subjects… a prediction of failure can be self-fulfilling by restricting a company's access to credit….” (CON
2:  Qualitative Characteristics of Accounting Information, Issued:
 May 1980, paragraph 55 – emphasis supplied.)

Mr. David R. Humphrey, Securities and Exchange Commission, September 22, 2005     Page 3

Also, an analogous situation was addressed in FAS 5 with respect to unasserted claims that are not likely of assertion:

“…With
respect to unasserted claims and assessments, an enterprise must
determine the degree of probability that a suit may be filed or a claim
or assessment may be asserted and the possibility of an unfavorable
outcome ... an enterprise may believe there is a possibility that it
has infringed on another enterprise's patent rights, but the enterprise
owning the patent rights has not indicated an intention to take any
action and has not even indicated an awareness of the possible
infringement.  In that case, a judgment must first be
made as to whether the assertion of a claim is probable.  If the
judgment is that assertion is not probable, no accrual or disclosure
would be required. On the other hand, if the judgment is
that assertion is probable, then a second judgment must be made as to
the degree of probability of an unfavorable outcome.  If an
unfavorable outcome is probable and the amount of loss can be
reasonably estimated, accrual of a loss is required by paragraph 8. If
an unfavorable outcome is probable but the amount of loss cannot be
reasonably estimated, accrual would not be appropriate, but disclosure
would be required by paragraph 10.  If an unfavorable outcome is
reasonably possible but not probable, disclosure would be required by
paragraph 10. (FAS 5:  Accounting for Contingencies, Issued: March 1975, paragraph 38, emphasis supplied.)

In
summary, the Company believes, strongly, that disclosures surrounding
hypothetical circumstances reasonably considered to be remote (and that
the passage of time has largely rendered moot) and that could result in
self-fulfilling prophecy are inappropriate, and has declined to include
such disclosure in the amended Form 10-KSB.  Were it ever to be
the case that the need for such disclosure became necessary, the
Company would include such disclosure when it became reasonably
possible the events, as described by Staff’s comment, could occur.

Item 7 – Financial Statements

Consolidated Statement of Operations, page F-5

3.

Please tell us what type of revenue is included in the “Other revenue” caption on your consolidated statements of operations.

The
following table shows the comparative breakdown of revenues for
calendar years 2004 and 2003, and will be included in the amended Form
10-KSB to be filed on approximately September 22, 2005:

Mr. David R. Humphrey, Securities and Exchange Commission, September 22, 2005     Page 4

Note 1 – Description of Business and Summary of Significant Accounting Policies

4.

We
note your response to our prior comment #6.  In this regard,
please tell us and revise your financial statement disclosures to
define list rental revenue.  Additionally, you state that you
recognize revenues “for the most part” in the period of
billing.  Supplementally, tell us why you believe it is
appropriate to recognize revenues at the time of billing.
 Further, tell us whether there were any billings that took place
prior to the use of the list rentals at December 31, 2004 and December
31, 2003 as well as the dollar amount for any such transactions.

List rental income for calendar year 2004 was $2,754.  (It was zero calendar year 2003.)

In
view of the amount, and as discussed with Staff, the Company does not
believe that the financial statement disclosures require amendment.

As
to recognition of the revenue, the time of billing is proximate to the
Company's performance of service and, inasmuch as the recognition
practice is consistently followed, the Company believes the policy is
appropriate.

The
Company does not believe there were any significant billings that took
place prior to the use of the list rentals at December 31, 2004 and
December 31, 2003.

5.

Supplementally tell us how you classified list rental income on your consolidated statements of operations.

In view of the deminimus amount, list rental income, as other income was netted against other expenses.

Mr. David R. Humphrey, Securities and Exchange Commission, September 22, 2005     Page 5

In
the amended Form 10-KSB to be filed on approximately September 22,
2005, the list rental income has been reclassified as other income.

10-QSB for the Quarterly Period Ended June 30, 2005

Item 1 – Financial Statements

Note 5 – Common Stock, page 16

6.

Tell
us the consideration received for the issuance of the 2,000,000 shares
held in escrow as security.  If no consideration was received,
such shares may not be validly issued and, therefore, they could not
serve as security for the $140,000 short-term note payable on demand to
an individual.

As discussed with Staff, there was no consideration received for the issuance of these shares.

After
further consideration, the Company believes these shares are better
described as contingently issuable inasmuch as the terms of the note
payable require the shares to be delivered to the holder of the note
only in the event of a default in repayment.

The
Company will amend the 10-QSB to reflect these shares as not issued and
outstanding and change the description of the transactions in the notes
to the financial statements accordingly,

*     *     *     *     *

In connection with this response to the matters enumerated above, the Company acknowledges that:

·

The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

·

Staff
comments or changes to disclosure in response to Staff comments 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.

Mr. David R. Humphrey, Securities and Exchange Commission, September 22, 2005     Page 5

*     *     *     *     *

Should there be any other questions or comments, please contact me.

Sincerely

Robert J. Salluzzo

Chief Operating Officer

C.

Mr. Juan Migone

Division of Corporate Finance

Via Facsimile Copy – 202 772 9202