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   Filed by Automated Filing Services Inc. (604) 609-0244 - Ikona Gear International, Inc. - Response Letter

March 8, 2005

 United States Security and

  Exchange Commission

  Washington, D.C. 20549-0510

  Attention: Meagan Caldwell, Staff Accountant

Dear Ms. Caldwell:

 We have reviewed your letter dated March 1, 2005 regarding
  the filings of Forms 10-KSB for the fiscal year ended August 31, 2004 and 10-QSB
  for the period ended November 30, 2004 for Ikona Gear International, Inc. (“the
  Company”) for (File No. 0-49664). We hereby provide you with our following
  responses relative to your questions:

    1.)
    By way of this letter we advise you of our proposed
        additional disclosures and to be applied prospectively to future 10-KSB
        and 10-QSB filings.

    2.)
    We acknowledge that, in connection with our responses
        to your questions, that:

           the Company is responsible for the adequacy and
            accuracy of the disclosure in their filings;

           our comments or changes to disclosure in response
            to SEC staff comments do not foreclose the Commission from taking
            any action with respect to the filing; and

           the Company may not asset staff comments as a
            defense in any proceeding initiated by the Commission or any person
            under the federal securities laws of the United States.

    3.)
    We believe we have adequately disclosed our accounting
        policy for measuring compensation costs for employees and non-employees
        in our significant accounting policy note (Note 3(h)). We believe further
        clarification may be desirable for our significant accounting policy note,
        to ensure no misinterpretations of its application, as in Note 8 to our
        form 10-KSB/A for August 31, 2004 We propose to add the following wording
        to the accounting policy note for stock options:

     -
     “the Company generally grants stock options
        with exercise prices equal to, or in excess of, the quoted market price
        at the date of the stock option grant”

     -
     The Company calculates compensation expense associated
        with non- employee stock-based compensation plans using the Black-Scholes
        model to estimate the fair value of options granted to non-employees.
        The Company classifies non-employee compensation expense according to
        the nature of services provided.

     Our Note 8 to the financial statements
        as presented in the Form 10-KSB/A for the year ended August 31, 2004 provides
        disclosure of the compensation expense associated with the application
        of SFAS 123 and our accounting policy for non-employee stock option compensation.
        Note 8 also provides the assumptions used in applying the Black-Scholes
        method to estimate the fair value of options issued to non-employees.

We trust that the above disclosures will provide suitable additional disclosures regarding the queries raised in your letter of March 1, 2005.

Regards,

 Raymond L. Polman, CA

  Chief Financial Officer

 1850 Hartley Avenue, Unit #1 • Coquitlam
  • British Columbia • Canada
  • V3K 7A1