SecProbe.io

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                          Vision Global Solutions Inc.
                           455 Notre Dame Street East
                                Montreal, Quebec,
                                 Canada H2Y 1C9

December 22, 2005

Securities and Exchange Commission
450 Northwest Avenue
Washington D.C.
20549-0304

      RE:   Vision Global Solutions Inc.
            Form 10-KSB for Fiscal Year Ended March 31, 2005
            Filed: July 19, 2005
            File No. 000-3114
            Attn: Brent Skinner, Christine Davis, Mark Kronforst.

Dir Sir/Madam:

      1.    We note that your principal office is located in Quebec, Canada and
            your auditors are located in Hollywood, Florida. We generally
            believe that there should be a logical relationship between the
            location from which the audit report is rendered and the location of
            a registrant's corporate offices or place where the registrant
            conducts its principal operations. Please explain to us why you have
            engaged auditors located in Florida and indicate whether they are
            licensed to practice in Quebec.

            Answer: Vision Global Solution Inc. is a Nevada Corporation having
            its office located in Quebec, Canada.. Being a reporting issuer in
            the United States, management believes that U.S. auditors would best
            serve the accounting principals generally accepted in the United
            States and by the Securities and Exchange Commission. Furthermore,
            we also retain the services of a Canadian audit firm Kosseim Labrie
            Inc. who are licensed to practice in Quebec and who work with the
            U.S. auditors. The audit of the Company's financial statements was
            performed in accordance with the procedures required by professional
            standards established by the Public Company Oversight Board of the
            Commission and auditing standards generally accepted in the United
            States. These standards and qualifications do not vary from state to
            state and, accordingly, we believe that the audit satisfies the
            requirements of the Commission. Rule SX 2-01 requires that an
            accountant be licensed and in good standing under the laws of the
            place of the accountant's residence or principal office. The rule is
            silent as to whether or not the accountant's state or country of
            licensure must coincide with the location of the registrant's
            corporate offices or place where the registrant conducts its
            principal operations.

Consolidated Balance Sheet

      2.    We note that you have recorded a note payable to a related party.
            Please tell us how you have considered the disclosure requirements
            of paragraph 2 of SEAS 57.

            Answer: The Company will amend the 10-KSB and re-file to include the
            disclosure requirements of SFAS 57 Related Party Disclosures.

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      3.    We note that you have classified your mandatorily redeemable
            preferred stock as a liability within your balance sheet. Explain to
            us why you believe such classification is appropriate and refer to
            the authoritative guidance that supports your accounting.
            Additionally, tell us how you have considered the disclosures
            required by SFAS 129.

            Answer: The mandatorily redeemable preferred stock has been
            classified in our balance sheet as a liability because it is a loan
            that the Company received from Investment Quebec, a governmental
            agency who aids companies operating in the Province of Quebec,
            Canada to pursue research and development. This loan was differed
            and guaranteed by the redeemable preferred shares no per value 3%
            cumulative dividends due beginning April 2008. The Company has
            adopted SFAS 150 - Accounting for Certain Financial Instruments with
            Characteristics of both Liabilities and Equity, and would also
            qualify as "Preferred Stocks Subject to Mandatory Redemption
            Requirements or Whose Redemption is Outside the Control of the
            Issuer" as defined by Accounting Series Release ("ASR") No. 268 -
            Redeemable Preferred Stocks.

Consolidated Statement of Stockholders' Deficit

      4.    We note that you have issued a significant number of shares as
            compensation for services. Please identify the recipients of these
            shares and explain to us the nature and timing of the services
            received. In addition, explain to us how you have accounted for
            these transactions and refer to the authoritative guidance that
            supports your accounting.

            Answer: The compensation was to outside consultants as disclosed in
            our Form S-8, filed on March 16, 2005. The services were rendered
            prior to the issuance and were contractually to be rendered
            subsequent to the date of issuance. Services included financial and
            business consulting services which would include evaluating various
            business strategies and recommending changes where appropriate and
            also critically evaluate Vision Global's performance in view of its
            corporate planning and business objectives, including but not
            limited to: Corporate Planning--(a) develop an in-depth
            familiarization with the issuer's business objectives and bring to
            its attention potential or actual opportunities which meet those
            objectives or logical extensions thereof, (b) alert the issuer to
            new or emerging high potential forms of product and distribution
            which could either be acquired or developed internally, (c) comment
            on the issuer's corporate development including such factors as
            position in competitive environment, financial performances vs.
            competition, strategies, operational viability, etc., and (d)
            identify prospective suitable merger or acquisition candidates for
            the issuer, perform appropriate diligence investigations with
            respect thereto, advise the issuer, with respect to the desirability
            of pursuing such candidates, and assist the issuer in any
            negotiations which may ensue there from.

            The Company valued the issuances at there fair market value on the
            date of issuance in accordance with SFAS 123.

Notes to Consolidated Financial Statements

Note 1 -- Summary of Accounting Policies Revenue Recognition

      5.    We note that you indicate, within your MD&A, that services are
            always included in the sate of software and represent installation,
            consulting, training and specific modifications to the software
            required by the customer. We further note that you recognize revenue
            in accordance with SOP 814 when, the software requires significant
            consultation and customization or modification of the software.
            However, your revenue recognition policy, as described within your
            financial statements, does not appear to be consistent with these
            disclosures. Please describe your typical arrangements to us in more
            detail and explain to us how you recognize the related revenue. In
            addition, reconcile your disclosures within your MD&A and your
            financial statements regarding revenue recognition.

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            Answer: Yes, services are included in the sale of the Software and
            represent installation, consulting, training and specific
            modifications to the software when requested by the customer.

            The Software sold to our customers is a standard version much like
            an out of the box software ready to be used as it is. This standard
            version is the product which is purchased by the customer. This
            revenue is recognized only once it is delivered and installed on the
            customer's server.

            Consulting and training services may for part of the contract in
            cases where the customer lack internal I.T. people or when they
            decide not to retain services of a 3rd party. These services are
            recognized when they have been rendered.

            Considering that the customer purchases a standard version of the
            software, they may request that we modify the standard version to
            meet their specific requirements. These revenues are recognized once
            the modifications have been completed, installed on the customer's
            site, tested by the customer and accepted by the customer.

      6.    We note that you have disclosed a policy of giving refunds to
            "unhappy customers," Please provide us with the following:

            o     Describe this policy to us in more detail and describe the
                  circumstances under which you offer such refunds;

            o     Provide us with the amount of refunds that have been granted
                  during the periods presented and your subsequent interim
                  periods;

            o     Explain to us how you have been able to conclude that your
                  fees are fixed or determinable in order to recognize revenue
                  under your arrangements; and

            o     Clarify for us why you believe it is appropriate to record
                  refunds as a reduction of revenue as they occur if the refund
                  is granted within one year of sale or as bad debt expense if
                  the refunds are granted beyond one year from the sale.

            Refer to the authoritative literature that supports your accounting
            and indicate how your accounting complies with that literature.

            Answer: Refunds are given to unhappy customers. Refunds are netted
            against sales if they occur in the year of the sale and are recorded
            as bad debts if they occur in the following year. Vision Global
            offers an independent warranty for a 1-year period for an
            agreed-upon up-front payment. It collects the amount up front and
            amortizes the revenue over the term of the coverage, with the
            unearned portion shown as deferred revenue.

            To date, no refunds have been requested or issued to any of our
            customers. We have, to a limited, de minimus degree, issued credit
            notes when our employees charged for services which were covered by
            our warranty.

      7.    You disclose that VSOE of fair value is based on the price
            management establishes prior to introduction into the marketplace.
            Please clarify for us whether you have sold separately any of the
            products or services for which VSOB has been established in this
            manner, Provide us with an analysis that indicates the date you
            began to recognize revenue under each arrangement using this method
            for establishing VSOE and the date that each affected element was
            subsequently sold separately.

            Answer: Revenue Recognition

            We generally sell our software products and services together in a
            multiple-element arrangement under both perpetual and term license
            arrangements. When we enter into a multiple-element perpetual
            arrangement, we use the residual method to allocate the total fee
            among the various

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            elements of the arrangement. Under the residual method, revenue is
            recognized when vendor-specific objective evidence, or VSOE, of fair
            value exists for all of the undelivered elements in the arrangement,
            but does not exist for one or more of the delivered elements in the
            arrangement. Each license arrangement requires that we analyze the
            individual elements in the transaction and estimate the fair value
            of each undelivered element, which typically includes maintenance
            and services. We allocate revenue to each undelivered element based
            on its fair value, with the fair value determined by the price
            charged when that element is sold separately.

            We generally estimate the fair value of the maintenance portion of
            an arrangement based on the maintenance renewal price for that
            arrangement. In multiple-element arrangements where we sell
            maintenance for less than fair value, we defer the contractual price
            of the maintenance plus the difference between such contractual
            price and the fair value of maintenance over the expected life of
            the product. We make a corresponding reduction in license revenue.
            The fair value of the professional services portion of the
            arrangement is based on the rates that we charge for these services
            when sold independently from a software license. If, in our
            judgment, evidence of fair value cannot be established for the
            undelivered elements in a multiple-element arrangement, the entire
            amount of revenue from the arrangement is deferred until evidence of
            fair value can be established, or until the elements for which
            evidence of fair value could not be established are delivered.

Consent of Independent Auditors

      8.    We note that the consent provided by Jewett, Schwarz & Associates
            appears to refer to an audit performed by Malone & Bailey, PLLC and
            does not appear to be dated. Please explain to us why you believe
            this consent complies with Item 601 of Regulation S-B.

            Answer: The reference to March 31, 2004 was inadvertent and is
            intended only for March 31, 2005. The consent of the former auditors
            to their report for 2004 was filed with the Form 10-KSB/A on
            September 15, 2004.

Section 302 Certification

      9.    We note that paragraph 4(d) refers to the quarter ended November 30,
            2004 and that your officers have provided certifications related to
            your internal control over financial reporting. Please explain to us
            why you believe that these certifications comply with Exhibit 31
            provided in Item 601 of Regulation S-B and the transition guidance
            in Section III.E of SEC Release 33-8238.

            The disclosure complies with the disclosure in 4(d) in that it is
            certified that the Company has disclosed in this report any change
            in the small business issuer's internal control over financial
            reporting that occurred during the small business issuer's fourth
            fiscal quarter that has materially affected, or is reasonably likely
            to materially affect, the small business issuer's internal control
            over financial reporting, except that the reference was intended to
            be to March 31, 2005, the end of the issuer's fourth fiscal quarter.

On behalf of the Company, we hereby affirm the following:

            o     the company is responsible for the adequacy and accuracy of
                  the disclosure in the filing;

            o     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

            o     the comp