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      ANSLOW & JACLIN, LLP

      RICHARD I. ANSLOW

      Counselors at Law

      EMAIL: RANSLOW@ANSLOWLAW.COM

      GREGG E. JACLIN

      EMAIL: GJACLIN@ANSLOWLAW.COM

December 5, 2005

Daniel H. Morris, Esq.

U.S. Securities and Exchange Commission

101 F Street

Mail Stop 3561

Washington, D.C. 20549

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

Registration Statement on Form SB-2, filed October 20, 2005

File No. 333-129153

Dear Mr. Morris:

The following is in response to your letter dated November 18, 2005:

General

1.

Please
revise throughout the document, as applicable, to explain why you are
required to register 200% of the common shares issuable in connection
with the callable secured convertible notes. We note that the
securities purchase agreement calls for liquidated damages to be paid
under certain circumstances in cash or in stock, at the option of the
investor. Ensure that your revised disclosure clearly addresses whether
any of the additional shares are being registered to cover shares that
may be issued in the event liquidated damages are due. If so, ensure
that you supplementally provide us with an analysis as to why you
believe it is appropriate to register such shares given that the
investors appear to have discretion with respect to receiving cash or
stock and appear not to have been irrevocably bound to purchase these
shares at the time the registration statement was filed. Refer to
Interp. A.51 of the July 1997 CF Manual of Publicly Available Telephone
Interpretations and refer, by analogy, to Interp. 3S of the March 1999
Supplement.

ANSWER:
 In Amendment No. 1 to Form SB-2, we registered 211,666,66 shares
as follows: (i) 5,000,000 shares are for the exact amount of shares
underlying the warrants issued in the September 23, 2005 financing,
specifically 5,000,000.  For the 206,666,666 shares, the
calculation was determined as follows: the closing price of the
Company’s common stock on the closing date of September 23, 2005
was $.06.  You multiply this

amount
by the 60% discount (or $.036).  You then divide the total
subscription price of $3,720,000 by $.036 resulting in 103,333,333
shares.  This amount is then multiplied by 200% pursuant to the
financing documents that require the Company to register 200% resulting
in 206,666,666 shares.

In
Amendment No. 1 to Form SB-2, we have filed the Registration Rights
Agreement related to the Company’s September 2005 financing.
Section 2.a. of the Registration Rights Agreement requires that the
Company register “…two (2) times the sum of the number of
Conversion Shares that are then issuable upon conversion of the Notes
and Additional Notes… and the number of Warrant Shares issuable
upon exercise of the Warrants, without regard to any limitation on the Investor’s ability to convert the Notes or exercise the Warrants.”

In
addition, pursuant to Section 2.c. of the Registration Rights Agreement
(which we are filing as Exhibit 10.10), the Company is required to pay
a penalty (defined as Standard Liquidated Damages as defined in the
Securities Purchase Agreement – see the definition of
“Registrable Securities” in Section 1.a.(iii) of the
Registration Rights Agreement).  The last sentence of Section 2.c.
states that the penalty “…shall be paid in cash or, at the
Company’s option, in shares of Common Stock…”

However,
as you stated above, Section 4h. of the Securities Purchase Agreement
states that the Investors have the right to receive cash or stock.
 Since this clause is inconsistent with the clause in the
Registration Rights Agreement, the Company and the Investors have
executed an amendment to the Securities Purchase Agreement to be
consistent with the Registration Rights Agreement and provides the
Company solely with the right to pay the penalty in cash or stock.
 The amendment has been filed as an exhibit in Amendment No. 1 to
Form SB-2.

About Us, page 1

2.

Please
expand your filing to provide a summary in order to provide context for
the financial data included in this section, as well as the information
that follows. For example, you include no description of your business
up front, which makes it difficult for investors to understand the risk
factors applicable to your business, or even what your plan of
operation is. In this regard, we note that investors aren=t given a
complete description of the business until page 11. Refer to Item 503
of Regulation S-B in preparing your summary, but ensure that in
addition to a brief description of your business, your summary also
briefly discusses your recent restatement, your history of net losses
and the fact that your revenues have declined over the past year.

ANSWER:  In Amendment No. 1 to Form SB-2, we have expanded our “About Us” section.

Risk Factors, page 1

3.

We
note that you recently restated your financial information. Please
revise to include a risk factor discussing any risks posed by the
restatement and ensure that you include a discussion regarding your
controls and procedures. While we note from your Form 10-Q filed
November 17, 2005 that management believed the Company’s controls
and procedures were effective as of September 30, 2005, you should
discuss whether, in light of the restatement, you continue to believe
your controls are effective, and the basis for such belief.

ANSWER: In Amendment No. 1 to Form SB-2, we have added the requested risk factor.

Our charter provides for limited liability for our directors and officers, page 3

4.

Please
clarify your disclosure in this section. To the extent that your
certificate of incorporation indemnifies individuals for the breach of
fiduciary duty of care as a director, it is not clear how officers or
stockholders are covered by that protection. Please identify the
indemnifications, if any, available to officer and stockholders.

ANSWER:
In Amendment No. 1 to Form SB-2, we have revised this risk factor to
delete any reference to indemnification to officers or stockholders
since the Company’s Certificate of Incorporation only provides
this to the Company’s directors.

Shares eligible for public sale...ability to raise capital, page 5

5.

Please
expand your disclosure to fully explain the risk presented to investors
as additional shares of your common stock become eligible for sale in
the future.

ANSWER: In Amendment No. 1 to Form SB-2, we have expanded the disclosure in this risk factor.

Market for Common Equity and Related Stockholder Matters, page 5

6.

The
escrow agreement between the Company and Mr. Stevens does not appear to
have been filed in the past. Please either file it as an exhibit to the
registration statement or advise.

ANSWER:
 At this point, Mr. Stevens has been paid in full and the
Company’s obligation to him has been extinguished.  We have
indicated this in Amendment No. 1 to Form SB-2.  Therefore, we are
not filing the escrow agreement.

Management’s Discussion and Analysis or Plan of Operation, page 7

7.

Please
comprehensively revise both this section and your business section, as
applicable, to provide better disclosure with respect to the different
types of services your provide and whether they produce revenues or are
promotional in nature. For example, do the events you describe here and
in your business section, such as WCD, events at baseball games and
military events, generate the “special projects income” to
which you refer on page 9 or are they purely promotional? Are your
clinical publications sold or provided at no cost? Revise to clarify
the nature of your products, services and business.

ANSWER:
In Amendment No. 1 to Form SB-2, we have revised and expanded the
MD&A section and business section to describe the different types
of services we provide and whether or not they produce revenues or are
promotional in nature.

8.

Revise
to disclose the basis for your belief that your core services are all
forecast to experience significant growth beginning in the fourth
quarter of 2005.

ANSWER:
In Amendment No. 1 to Form SB-2, we have disclosed the basis for the
Company’s belief that its core services will experience growth in
the fourth quarter of 2005.

Plan of Operations, page 7

9.

In
the last paragraph of this section, you describe your submission of an
appropriations request to Congress. Please expand these disclosures to
state how such funds, if received, will be accounted for in your
financial statements.

ANSWER: In Amendment No. 1 to Form SB-2, we have added the following paragraph at the end of the Plan of Operations section:

“In
March 2005, we submitted an appropriations request in the amount of
$1,000,000 to Congress. If approved and funded in 2006, this would
increase our education and information programs to military families
with special needs dependents and caregivers. If successful in having
these funds committed, we intend to build upon our existing
relationships within the military community to bring timely and
meaningful educational content in both print and on a web based
delivery system to these families but also to the physicians charged
with their care.  In this regard, we have already begun this
process delivering high quality educational content through highly
respected military hospitals such as Walter Reed Army Medical Center,
Brooke Army Medical Center and the Uniformed Medical Services School in
Bethesda, all focused in the area of chronic long term care. This

initiative,
once operational, would result in increased revenue from subscriptions,
on-line interactive training sessions and custom communication sales.
We would account for all revenues consistent with existing accounting
policy which is to identify revenue streams consistent with our core
services which are subscriptions, page advertising, and special
projects/custom communications and on line web based programming. We
would also identify these revenue streams as being generated from
military funding so as to distinguish the revenue streams from those
funded by private sponsorship.

While
we cannot predict the ultimate outcome of the appropriations process,
we have been notified that the appropriation has received committee
approval and is now with the House of Representatives and Senate for
their respective final reviews and passage.”

Liquidity and Capital Resources, page 9

10.

Please
disclose here the identity of the private investment firm that received
a commission in connection with this transaction.

ANSWER:
In Amendment No. 1 to Form SB-2, we have identified the private
investment firm, specifically Westminster Securities Corporation.

11.

Please
expand your disclosure to provide a discussion of the material terms of
your credit agreement with Provident Bank, including quantified
disclosure of any material financial covenants.

ANSWER:
 To date, Provident Bank’s loan has been paid in full and
the credit agreement was terminated.  Therefore, we have not added
any additional disclosure in Amendment No. 1 to Form SB-2.

12.

Expand
this section to state the minimum period of operations you are able to
fund using your current capital resources as well as any additional
contractually committed capital you are entitled to receive. Disclose
the current rate at which you are using capital in operations and
describe how you plan to address any deficiency. Additionally, indicate
both here and in the prospectus summary whether your current capital
resources plus additional capital contractually committed to you is
sufficient to fund your planned operations for a period of no less than
twelve months from the date of the prospectus.

ANSWER:
In Amendment No. 1 to Form SB-2, we have added the following language
at the end of the “Liquidity and Capital Resources” section:

“With
an existing forecast of minimum revenues of $4,000,000 in 2006,
management believes that with the operational cash to be generated and
the retained working capital from our recent funding as well as the
remaining $1,000,000 of funding to be received, the overall cash
requirements of operations are expected to be met. While there is no
absolute guarantee that we will generate the forecast revenues or that
we will receive the remaining $1,000,000 of funding, which is dependent
upon this filing becoming effective, management believes that both the
revenue generation forecast and the additional funding will be
attained.

At
the present level of operations, working capital requirements to
sustain operations approximates $250,000 per month exclusive of any
existing debt service that approximates an additional $7,000 per month.

To
provide additional liquidity, management expects, within the next 90
days, to apply for a line of credit secured by accounts receivable. A
previously held line of credit in the amount of $450,000 had been paid
off pursuant to the requirements of the securities purchase agreement
under which $2,000,000 has been received to date. Although there is no
assurance that we would be able secure such funding, management
believes that with its improved working capital ratios and its
improving revenue production it is reasonable to believe that a working
capital line would be able to be secured.

Should
forecast revenues trend toward 2005 levels of a forecast of $3,000,000,
the additional liquidity provided by a line of credit as well as an
increase in reliance on trade debt it is believed, would in the short
term provide the liquidity to support operations while adjustments are
considered to bring revenues back on plan.  It should be noted
that trade debt has been reduced from $600,000 (pre-funding) to under
$200,000 (post-funding).

It
is management’s estimate that with its existing working capital
resources and with the insurance of the contemplated additional funding
noted, we will be able to meet the working capital requirements of
operations for the coming twelve months of operations.”

Results of Operations, page 9

13.

Please
substantially revise this section to clearly convey and address the
trends in your business. Your disclosure should reflect yearly results
and changes (both in the aggregate and relative to past performances),
and in each case, fully discuss the significance of such results and
changes. Refer to Item 303 of Regulation S-B. Additionally, this
section should describe, in quantified terms, any agreements or
arrangements that materially affect the Company=s operations. For
example, we note from page 18 that EBSCO is to provide you with
royalties equal to 20% of the net revenue collected on products sold by
them. Revise accordingly.

ANSWER: In Amendment No. 1 to Form SB-2, we have substantially revised this section.

14.

Please
expand your disclosures to include a detailed description of how you
used the net proceeds of $1,250,000 received to date and how you plan
to use the remaining proceeds from the $3,720,000 of financing obtained
on September 23, 2005. For example, please discuss whether proceeds
will be used to pay down outstanding debts, such as the $140,000 owed
to Mr. Giltner Stevens and how the 2,000,000 shares currently held in
escrow as contingent security will be affected.

ANSWER:
In Amendment No. 1 to Form SB-2, we have added an expanded disclosure
regarding how the Company used net proceeds of $1,250,000 and how it
will use the balance of the net proceeds from the funding transaction.

About Us, page 12

15.

Please
revise the first sentence of the second paragraph of this section to
delete reference to your “tradition of excellence.” In
addition, please carefully review your filing to remove other
unsubstantiable, marketing terms and phrases (for example, your
reference on page 7 to your “heritage of providing
‘Information that matters from those who care’’).

ANSWER:
In Amendment No. 1 to Form SB-2, we have removed the part of the first
sentence of the second paragraph stating “tradition of
excellence” and any other marketing terms.

16.

As
a follow-up to the comment above, please provide support for your
statement on pag