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CORRESP
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    SMI
      Products, Inc.

    122
      Ocean
      Park Blvd.

    Suite
      307

    Santa
      Monica, CA 90405.

    Tel.
      (310) 396-1691

    November
      9, 2006.

    By
      EDGAR Transmission and by Hand Delivery

    Raquel
      Howard

    Staff
      Accountant

    U.S.
      Securities and Exchange Commission.

    100
      F
      Street N.E.

    Washington,
      D.C. 20549.

              Re:
                SMI Products, Inc.

              Item
                4.01 Form 8-K

              Filed
                November 8, 2006

              File
                No. 3-55166

    Ladies
      and Gentlemen:

    On
      behalf
      of SMI Products, Inc. (the “Company”), we hereby submit the Company’s responses
      to the comments of the staff (the “Staff”) of the Securities and Exchange
      Commission (the Commission) set forth in the Staff’s letter, dated November 9,
      2006, providing the Staff’s comments with respect to the above referenced Form
      8-K Current Report (the “Report”).

    For
      the
      convenience of the Staff, each of the Staff’s comments is included and is
      followed by the corresponding response of the Company. References in this letter
      to “we”, “us” and “our” refer to the Company unless the context indicates
      otherwise.

          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.

    COMPANY
      RESPONSE.
      We have
      revised our disclosure to consistently state that Amisano Hanson was dismissed
      and we have stated that such dismissal took place on October 31,
      2006.

          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 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.

      U.S.
        Securities and Exchange Commission

      November
        9, 2006

      Page
        2

    COMPANY
      RESPONSE.
      We have
      revised our disclosure to include the disclosures required by Item
      304(a)(1)(ii) of Regulation S-B. We have also included the language from Amisano
      Hanson’s Reports for the years ended December 31, 2004 and December 31, 2005
      with respect to their “going concern” opinion.

          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.

    COMPANY
      RESPONSE.
      We have
      amended our disclosure to state the “year ending December 31, 2006”.

          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.

    COMPANY
      RESPONSE.
      We have
      filed as Exhibit 16 a letter from Amisano Hanson with respect to the revised
      Item 304 disclosures

    The
      Company further acknowledges as follows:

          ·

            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,

    If
      you
      would like to discuss any of the responses to the Staff’s comments or if you
      would like to discuss any other matters, please contact Robert L. B. Diener
      at
      (310) 396-1691.

              Sincerely,

              SMI
                PRODUCTS, INC.

              By:

                /s/ Geoffrey
                Alison

                Geoffrey Alison

                Chief Executive Officer.

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