SecProbe.io

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      Mail Stop 7010
      September 13, 2005

By U.S. Mail and Facsimile

Ms. Shannon Downs
Chief Financial Officer
Canadian Rockport Homes International, Inc.
700 West Pender Street, Suite 507
Vancouver, B.C. Canada V6C 1G8

Re:	Canadian Rockport Homes International, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
      	File No.  333-62786

Dear Ms. Downs:

      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 comments are 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
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.

General

1. Please file all appropriate Exchange Act filings, including,
but
not limited to the current delinquent Form 10-Qs.

Form 10-K for the Fiscal Year Ended December 31, 2004

General

2. Please revise to provide your selected quarterly financial data
as
required by Item 302 of Regulation S-K.
Selected Financial Data, page 7

3. Please revise to provide your selected financial data for each
of
the last five fiscal years as required in Item 301 of Regulation
S-K.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 9

Liquidity and Capital Resources, page 12

1. Given your auditor`s substantial doubt about your ability to
continue as a going concern, please revise your filing to provide
a
discussion of how you intend to finance your operations for the
next
twelve months as provided in section 607.02 of the SEC
Codification
of Financial Reporting Policies (FRR-16), Uncertainty About an
Entity`s Continued Existence.

2. Please tell us, and revise your filings to disclose, your
estimate-to-completion on the construction of the plant in Lampa,
Chile, as well as how much of this amount you expect to spend over
the next 12 months.  In addition, please discuss the changes in
the
construction-in-progress account from period to period and how the
agreement that was concluded with TWiC in 2004 impacts future
manufacturing of molds and the supply of services required for
construction of the Chilean plant.  See Section IV. of Release No.
33-8350, Interpretation - Commission`s Guidance Regarding
Management`s Discussion and Analysis of Financial Condition and
Results of Operations for guidance.

6. Please revise to provide a table of contractual commitments as
required by Item 303(A)(5) of Regulation S-K.

Financial Statements, page F-1

Report of Independent Registered Public Accounting Firm, page F-2

7. Please have your independent registered public accounting firm
revise its audit opinion to include the city and state where the
audit opinion was issued as required by Rule 2.02(a) of Regulation
S-
X.

8. Your independent accountant, Jonathon P. Reuben, CPA, is duly
registered and in good standing to practice in California.
However,
it is unclear to us whether Jonathon P. Reuben, CPA, was and is
currently licensed in Vancouver, B.C. Canada where your executive
offices are located.  Please note that it is your responsibility
to
provide financial statements audited by an auditor who meets the
requirements of Rule 2-01(a) of Regulation S-X.  Please tell us
how
you have met the requirements of Rule
2-01(a) of Regulation S-X.  In addition, since a significant
portion
of your operations are in Chile, detail for us the audit
procedures
conducted in that country.

Consolidated Balance Sheets, page F-3

9. We note that you acquired 598546 B.C. Ltd. from a related party
shareholder for 200,000 shares of common stock in June 2002. We
also
note that you sold the truss plant and timber in the same month at
a
substantial loss.  Tell us the basis for the original allocation
of
the purchase price to the various assets. Considering these
substantial losses, help us better understand how you determined
that
there was no impairment of value of the $400,000 attributed to the
land.

Consolidated Statement of Stockholders` Equity (Deficit), page F-7

3. It appears that a page from your consolidated statement of
stockholders` equity is missing and has been replaced with a
duplicate page of F-9.  Please revise your statement of
stockholders`
equity to include the correct pages of the financial statement,
for
all appropriate periods.

Note 1 - Property and Equipment, page F-14

11. Please revise to disclose the details and activity of the
construction-in-progress account.

Item 9A - Controls and Procedures, page 15

4. You disclose that your evaluation of the effectiveness of
disclosure controls and procedures was conducted within 90 days
prior
to the filing of your Form 10-K.  Please revise your disclosure to
state that management`s evaluation was as of the end of the fiscal
year as stated in Rules 13a-15(c) and 15d-15(c).

5. Given that your Exchange Act filings were not timely filed
during
fiscal 2004 and fiscal 2005, please explain to us how your
"Principal
Executive Officer and Principal Financial Officer concluded that
the
disclosure controls and procedures are effective" to ensure that
information required to be disclosed by you in the reports filed
or
submitted under the Exchange Act were recorded, processed,
summarized
and reported, within the time periods specified in the
Commission`s
rules and forms.

*	*	*

      Please respond to these comments within 10 business days, or
tell us when you will provide us with a response.  Please provide
us
with a response letter that keys your responses to our comments
and
provides any requested information.  Detailed letters greatly
facilitate our review.  Please file your response on EDGAR as a
correspondence file.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include 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 comment, please provide,
in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* 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.

     In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

     If you have any questions regarding these comments, you may
contact Dale Welcome, Staff Accountant, at (202) 551-3865, John
Hartz, Senior Assistant Chief Accountant, at (202) 551-3689 or, in
their absence, to the undersigned at (202) 551-3768.

      Sincerely,

      John Cash
								Accounting Branch Chief
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Ms. Shannon Downs
Canadian Rockport Homes International, Inc.
September 13, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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