SecProbe.io

Mail Stop 3561
        November 9, 2006

Geoffrey Alison, Chief Executive Officer
SMI Products, Inc.
122 Ocean park Blvd.
Suite 307
Santa Monica, CA 90405

Re: SMI Products, Inc.
 Item 4.01 Form 8-K
 Filed November 8, 2006
 File No. 3-55166

Dear Mr. Alison:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with more information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

1. We note your disclosure that you will discontinue the services of Amisano Hanson Chartered Accountants.  This statement appears inconsistent with your disclosure that you have dismissed your former accountant.  Please revise your disclosure to clarify your statement and disclose the specific date the former accountant was dismissed as required by Item 304(a)(1)(i) of Regulation S-B.

2. We note that that the former accountant audited your financial statements for the two most recent fiscal years ended December 31, 2005 and 2004.  Please revise your disclosure to address whether the former accountant’s
reports  on your
financial statements for either of the past two years contained an adverse opinion
or disclaimer of opinion, or were modified as to uncertainty, audit scope, or

Geoffrey Alison
SMI Products, Inc.
November 9, 2006 Page 2
accounting principles, which would include the uncertainty regarding the ability to continue as a
going concern .  See Item 304(a)(1)(ii) of Regulation S-B.

3. We note that your disclosure under 4.01(b) refers to the year ended September 30, 2006, rather than the year ended December 31, 2006.  Please revise or advise.

4. Please obtain and file an Exhibit 16 letter from the former accountant stating whether the former accountant agrees with your revised Item 304 of Regulation S-B disclosures, or to the extent to which the accountant does not agree.

As appropriate, please amend your filing and respond to these comments within
five business days or tell us when you will respond.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging 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.

Geoffrey Alison
SMI Products, Inc.
November 9, 2006 Page 3
In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.

If you have any questions, please call Raquel Howard at (202) 551-3291.

Sincerely,

Raquel Howard
Staff Accountant