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MAIL STOP 0511
	November 5, 2004
Gerald J. Shields
President
Trend Technology Corporation
Suite 1020
510 Burrard Street
Vancouver, British Columbia
V6C 3A8 Canada

RE:	Trend Technology Corporation
	Registration Statement on Form 10-SB12G
	File No. 000-50978
	Filed on October 7, 2004

Dear Mr. Shields:

	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 supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not 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 on any other aspect of
our review.  Feel free to call us at the telephone numbers listed at
the end of this letter.  Page references refer to the marked courtesy
copy provided to the staff.

Facing Page of Form 10-SB

1. Please revise your facing page to indicate whether any securities
are being registered under Section 12(b) of the Act.

Description of Business

2. We note your statement that "during the period March, 2003 to
September, 2003, we scouted locations in British Columbia for the
potential staking of claims."  We also note statements in the Notes to
Financial Statements that the company commenced operations on November
14, 2003.   Finally, we note your statement in the Plan of Operation
section "during the period June to December, 2003 we obtained stock
subscriptions ... this financing activity was done concurrently with
our start up exploration activities."  Please revise your disclosure
or advise us how the statements are consistent.

3. Revise to provide the details of your offering from October to
December 2003.  Indicate the amount of money raised and the number of
shares sold.  Disclose the number of investors in your offering.

4. We note your statement that "further exploration will be required
before a final evaluation is made as to economic and legal feasibility
of our property."   Clarify your reference to the "legal feasibility"
of your property.  We may have further comment.

5. Revise to identify who has been commissioned to provide a
comprehensive technical report on your property.

6. We note your statement that "we staked our Copper Prince property
in South Central British Columbia ...."  Supplementally advise us who
staked your claims.  Also advise us whether the person(s) who staked
your claims received compensation from the company.   We may have
further comment.

7. Indicate what minerals the company is seeking in its exploration
activities.

8. Revise to indicate your competitive position in the mining
industry.

9. Address the availability of supplies used for your exploration
activities.

10. Revise to describe the applicable mining regulations in Canada.

11. We note your statement "we are not in a business which requires
governmental approval for principal products or services."  We do not
understand your statement given your disclosure that numerous
government approvals are necessary in order to commence mining.
Revise as appropriate.  Also address whether the company need
governmental approval to conduct its exploration program.

12. You state that if you are unable to raise capital to pay for
extensive claim exploration, you will enter into joint ventures;
however, you have no plan to raise additional funds in the next 12
months.  Please clearly state whether you will have to raise capital
to pay for claim exploration.

13. You state that you will acquire new properties through option
agreements where new properties can be acquired on favorable terms.
Please explain the types of businesses you are seeking.  Also,
indicate whether you have entered into negotiations or agreements,
preliminary or otherwise, with any potential acquisitions.  Please
explain how you plan to acquire properties through option agreements.
Please explain how and who will find new properties to acquire and
whether anyone will receive finders` fees.

14. Provide information required by Item 101(c) of Regulation S-B
regarding reports to security holders.

15. Please disclose that you are filing this Form 10-SB on a voluntary
basis and explain the reason(s) for the filing.

16. We note the statement that your "consultants have extensive
industry experience and are familiar with all government approvals in
order to comment mining."  Please revise any language that reflects
Trend Technology`s opinion or is promotional in nature through out the
prospectus.  Furthermore, please disclose the identities of your
consultants and describe the principal terms of any agreements with
them.  Material agreements should also be filed as exhibits.

17. We note the statement "we have not expended any funds on research
and development activities and do not expect to do so in the
foreseeable future."  Please revise the disclosure to discuss the
costs of research and development activities you conducted in phase 1.

18. Please disclose the minimum number of hours per week your officers
will devote to your business.

19. Clarify whether you anticipate using company employees,
consultants or contractors to perform your exploration.

Plan of Operation, page 8

20. You state that during the period of June to December, 2003, you
obtained stock subscriptions for 9,202,300 shares at $0.01 per share
to raise proceeds of approximately $99,000.  If the shares were sold
at $0.01 per share, you would have raised $92,023.  Further, on page
21, you disclose that you issued 9,902,300 shares on March 31, 2004.
Please reconcile inconsistencies or clarify the statements.

21. Please clearly disclose the amount of capital you allocate to
cover the general and administrative expenses for the next 12 months
and the amount you will allocate to acquire additional mineral
exploration prospects.

22. We note your statement that "the property is approximately 12 km
north-northeast of Princeton Mining Corp.`s Copper Mountain mine which
currently has three productive orebodies."  We do not understand why
you have included the reference to Princeton Mining Corp.`s Copper
Mountain mine.  Having a property with a productive mine near your
property does not indicate that there are any recoverable minerals on
your mining claims.  Revise to delete the noted statement or advise us
of the basis for your statement.

23. Explain the statement, "[a] Geographical Information System (GSI)
was set up for the enlarged property using North America Datum 1983 as
the grid points for all past and future surveys."

24. Indicate the number of rock samples taken in Phase I and sent to
Acme Analytical Laboratories.

25. Describe in more detail the activities you performed in your Phase
I exploration.

26. Describe in more detail the activities you will perform in your
Phase II exploration.  It is not clear from the prospectus what Phase
II entails.  Is there a Phase III or IV?  Please discuss precisely the
activities that you plan to engage in each phase.

27. Describe in greater detail your proposed program of exploration
beyond Phase II.

28. In discussing your plan of operations for the next twelve months
as required by Item 303(a) of Regulation S-B, please provide detailed
milestones to the business plan, including a discussion of the
milestones you have yet to achieve and the specific steps needed to
accomplish each milestone.  Also provide a timeline for reaching each
milestone in weeks or months.  In your discussion, provide a detailed
analysis of the costs of each step and how you intend to finance this
project.  We may have further comment.

29. Clarify when during the year exploration activities maybe
conducted at your properties.

Description of Property

30. Clarify whether the company`s agreement with Mr. Gerald Shields
regarding the office space is a legally enforceable agreement.

31. Supplementally provide us copies of Figure 1, Figure 2 and Figure
3 reference in this section.

Security Ownership of Certain Beneficial Owners and Management, page
18

32. Please identify the officers and directors of the company in your
beneficial ownership table.

33. Please confirm the number of shares presented in the table include
the amount of shares with respect to which the persons have the right
to acquire within 60 days pursuant to options, warrants, conversion
privileges or other rights.

34. We understand that Gerald R. Tuskey, a beneficial owner of 30.29%
of your shares, is also your legal counsel for this filing.  Please
advise on a supplemental basis the date and manner Mr. Tuskey acquired
the shares and the price he paid for the shares.  We also refer you to
the definition of "promoter" under Rule 405 of Regulation C and if
applicable, you should provide the full disclosure required by Item
404(d) of Regulation S-B regarding Mr. Tuskey.

35. Revise to indicate the number of shares of common stock
outstanding.

Directors, Executive Officers, Promoters and Control Persons, page 19

36. Please disclose the identities of your officers and directors
before April 2004.

37. Please disclose the beginning date of Mr. Shields` directorship
with SCS Solar Computing Systems Inc. and its business.

38. Indicate the business conducted by Resource Management Associates.

39. You state that your officers and directors may be involved with
other companies in the future and direct conflicts of interest may
arise.  Please discuss whether the officers and directors plan to
become involved with another mining company.  Also, please address
their fiduciary duty towards the company and the shareholders.

Executive Compensation, page 20

40. We note that Mr. Gerald Shields and Mr. Leonard MacMillan own
50,000 and 5,600 shares respectively.  Supplementally advise us when
they acquired their shares and the compensation they paid for those
shares.  Also tell us whether the consideration they paid per share is
the same as the other investors in the company.  We may have further
comment.

Certain Relationships and Related Transactions, page 20

41. Please provide the information required by Item 404(d) of
Regulation S-B.

Description of Securities, page 20

42. Please remove the statement, "[a]ll shares of our common stock
issued and outstanding are fully paid and non-assessable" as you are
not authorized to make such a statement.

Part II

Market Price of and Dividends on the Registrant`s Common Equity and
Related Stockholder Matters, page 22

43. Revise to indicate the amount of common stock that could be sold
pursuant to Rule 144 under the Securities Act.  Also provide more
detail regarding Rule 144.

44. Please confirm there are no securities authorized for issuance
under equity compensation plans.

Recent Sales of Unregistered Securities, page 22

45. Please confirm that all securities are sold for cash; otherwise,
disclose the information required by Item 701(c) of Regulation S-B.

46. Disclose the facts supporting your reliance upon Rule 506 of
Regulation D as an exemption for these transactions, as required by
Item 701(d) of Regulation S-B. Please make the representation that
there were no general solicitation or advertising.

47. We note your statement that "the purchasers who received shares
under Rule 506 of Regulation D warranted their eligibility as an
`Accredited Investor` as that term is defined in Regulation D".
Please note that you must make an independent determination of each
purchaser`s qualification as an accredited investor in a private
placement; it is insufficient in our view to solely rely on an
investor`s own representations.  Revise the disclosure to clarify that
the company made the determination that each investor was an
accredited investor.

Part - Financial Statements
Accounting Policies

48. Please clarify the second paragraph of Note 2(h) to indicate that
the company does not presently report promissory notes, other
receivables, accounts payable or accrued liabilities in its financial
statements.

General

49. Please disclose the company`s intended fiscal year end in a note
to the financial statements.

50. Your attention is directed to Item 310(g) of Regulation S-B and
the need for updated financial statements and related disclosures.

Engineering Comments

General

51. For your property, provide the disclosures required by Industry
Guide 7 (b).  In particular, provide:
* The location and means of access to the property,
* A map(s) showing the location of your properties.
* Any conditions that you must meet in order to obtain or retain title
to the property.
* A brief description of the rock formation and mineralization of
existing or potential economic significance on the property.
* A description of the present condition of the property.
* A description of any work completed on the property.
* A description of equipment and other infrastructure facilities.
* The current state of exploration of the property.
* The total cost of your property incurred to date and planned future
costs.
* The source of power that can be utilized at the property.
If applicable, provide a clear statement that the property is without
known reserves and the proposed program is exploratory in nature.
Refer to Industry Guide 7 (b)(1)-(5) for specific guidance.  Industry
Guide 7 can be reviewed on the Internet at
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7.

52. Insert a small-scale map showing the location and access to your
property.  Note that SEC`s EDGAR program now accepts digital maps, so
please include these in any future amendments that are uploaded to
EDGAR.  It is relatively easy to include automatic links at the
appropriate locations within the document to GIF or JPEG files, which
will allow the figures and/or diagrams to appear in the right location
when the document is viewed on the Internet.  For more information,
please consult the EDGAR manual, and if you need addition assistance,
please call Filer Support at 202-942-8900.  Otherwise, provide the map
to the staff for our review.

53. Remove all references in the document that use the term "mining"
or "mining operations," or any term that can imply mineral production,
such as "operations."  In particular, substitute the term "mineral
exploration" for "mining operations" or "mining exploration."

54. Unless you can substantiate significant technical training and/or
experience in minerals exploration or mining by members of your
management, you need to fully disclose that your management lacks
technical training and experience with exploring for, starting, and/or
operating a mine.  With no direct training or experience in these
areas, your management may not be fully aware of many of the specific
requirements related to working within this industry.  Their decisions
and choices may not take into account standard engineering or
managerial approaches mineral exploration companies commonly use.
Consequently, your operations, earnings, and ultimate financial
success could suffer irreparable harm due to management`s lack of
experience in this industry.

Description of Business, page 3

55. In the first paragraph of the Business Development section, you
refer to development activities.  "Development" and "production" have
very specific meanings under Industry Guide 7(a)(4), (see
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7).
They reference the "development stage" when companies are engaged in
preparing reserves for production, and "production stage" when
companies