SecProbe.io

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                                                            Trombly Business Law
                                                     1163 Walnut Street, Suite 7
                                                                Newton, MA 02461
                                                        Telephone (617) 243-0060
                                                        Facsimile (309) 406-1426

Amy  M.  Trombly,  Esq.
amy@tromblybusinesslaw.com

September  20,  2005

Delivered  by  electronic  submission  via  EDGAR

United  States  Securities  and  Exchange  Commission
Division  of  Corporation  Finance
100  F  Street,  N.E.,  Mail  Stop  7010
Washington,  DC  20549

     Attn:     Ms.  Pamela  A.  Long

     Re:     Xtreme  Companies,  Inc.
             Amendment  No.  2  to  Registration  Statement  on  Form  SB-2
             Filed  September  16,  2005
             File  Number:  333-127825
             Form  8-K  Item  4.01
             Filed  September  15,  2005
             File  No.  0-30914

Dear  Ms.  Long:

I  am  securities counsel for Xtreme Companies, Inc. (the "Company").  I enclose
for  filing  under  the  Securities  Act of 1933, as amended, Amendment No. 3 to
Registration  Statement  No.  333-127825, together with certain exhibits thereto
(the  "Registration  Statement").

Amendment  No. 3 to the Registration Statement contains revisions that have been
made  in  response  to  comments  received  from the staff of the Securities and
Exchange  Commission  (the  "Staff")  in  their letter dated September 20, 2005.

Set  forth  below  are  the  Company's  responses  to the Staff's comments.  The
numbering  of  the  responses  corresponds  to  the numbering of comments in the
letter  from  the  Staff.

Amendment  No.  2  to  Registration  Statement  on  Form  SB-2
--------------------------------------------------------------
Dilution,  page  9
------------------

Comment 1.     It appears that you have a typo in the last sentence of the first
paragraph  of  this  section on page 9.  We note your statement that the example
you  provide  showing  dilution to new investors is at an offering price of $.20
per  share,  but  that  you  use  the  current market price of $.15 per share in
performing the actual calculation.  Please revise the first statement to reflect
the  current  market  price,  which  is  used  throughout  your  document.

Response  1.     The  Company  has  made  the  change  requested  by  the Staff.

Exhibits
--------
Exhibit  5.1,  Legality  Opinion
--------------------------------

Comment  2.     The  legality  opinion  must  opine on the corporate laws of the
state  of  incorporation.  Please  confirm  to us supplementally that by General
Corporation  Law  of  the State of Nevada, counsel means all statutes, including
the  rules  and  regulations  underlying  those  provisions,  and the applicable
judicial  and  regulatory  determinations,  and  provisions  of  the  Nevada
Constitution  that  affect  the  interpretation  of the General Corporation Law.

Response 2.     Counsel confirms that by General Corporation Law of the State of
Nevada,  counsel  means  all  statutes,  including  the  rules  and  regulations
underlying  those  provisions,  and  the  applicable  judicial  and  regulatory
determinations,  and  provisions  of  the  Nevada  Constitution  that affect the
interpretation  of  the  General  Corporation  Law.

Comment 3.     We note that counsel consents to filing the opinion as an exhibit
to  the  registration  statement.  Please have counsel revise to also consent to
being  named  in  the  prospectus.

Response  3.     Counsel  has  made  the  requested  revision.

Form  8-K  Item  4.01
---------------------

Comment  4.     Please  advise  us  about  the  following:
-     We were unable to confirm that you independent accountant, Jaspers + Hall,
PC  is  currently  licensed  in  Missouri.
-     Tell us why you selected a Colorado accounting firm to perform your audit.
-     Tell  us  if  the  audit  was  performed  in  Colorado  or  Missouri.
-     Tell  us  how  you  have  met  those  requirements  to  provide  financial
statements  audited  by an auditor who meets the requirements of Rule 2-01(a) of
Regulation  S-X.
-     Tell us what consideration you have given to Missouri state laws governing
audits  of Missouri companies performed by accountants who are licensed by other
states.

Response  4.     Jaspers  +  Hall  is not currently licensed in Missouri, and to
date,  has  completed the unaudited reviews of the Company in Colorado where the
firm  is  a  current  member  of  the  state  accountancy  board.

     Certain  directors  of  the  Company  were familiar with Jaspers + Hall and
considered  Jaspers  +  Hall  as well as other accounting firms when determining
which  firm to select as independent auditors.  The Board looked at many factors
including  competency,  professionalism  and  cost.  The Company chose Jaspers +
Hall  as  a  result  of  this  analysis.

     The  Company's  2004  year  end  audit was completed in Colorado, where the
auditors at that time, Michael Johnson & Co, principal officers are located; and
in  California, where the Company's principal offices were located at the end of
2004.    Michael Johnson is registered and in good standing with the state board
of  accountancy  in  California.

     Rule 2-01 (a) states: (a) The Commission will not recognize any person as a
certified  public  accountant who is not duly registered and in good standing as
such  under  the  laws  of  the  place of his residence or principal office. The
Commission  will  not  recognize any person as a public accountant who is not in
good  standing  and  entitled to practice as such under the laws of the place of
his  residence  or  principal  office.

     The  Company  has  carefully reviewed this option when choosing an auditor,
and  both  Michael Johnson & Co who completed the year end 2004 audit is in good
standing  in  the  place of residence of their firm.  Jaspers + Hall, PC is, the
Company's current auditors, are also duly licensed and in good standing with the
state  of  Colorado.

     The  Company  and  the auditors have given substantial consideration to the
state  laws  governing  the  audits  performed  by accountants licensed in other
states, and the auditors have plans to be in full compliance with Missouri state
accountancy  laws  prior  to  the 2005 audit completion.  The Company recognized
this  policy when completing its 2004 year end audit as it chose a firm that was
duly  licensed  in  the  state  where  the firm resides as well as the state our
principal  offices  reside,  California,  at  the  time  of  the  audit.

If  you  have further questions or comments, please feel free to contact us.  We
are  happy  to  cooperate  in  any  way  we  can.

                              Regards,

                              /s/  Amy  M.  Trombly

                              Amy  M.  Trombly
                              Counsel  for  Xtreme  Companies,  Inc.

cc:     Xtreme  Companies,  Inc.

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