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MAIL STOP 0511

	March 30, 2005

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
	Amendment 1 Filed on February 11, 2005

Dear Mr. Shields:

      We have reviewed your amended 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.

General

1. Please amend your letter of January 17, 2005 to include the
following acknowledgement, as requested in our letter dated
November
5, 2005:  "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."

2. Supplementally, with a view towards disclosure, provide us with
a
listing of the following information: (1) every public entity with
which any principal, or any affiliate of either a principal or the
company (specifically including Gerald Tuskey, William Ebert,
Gerald
Shields, Leonard MacMillan and Gerry Diakow) has been or is
associated with, including but not limited to such principal`s or
affiliate`s involvement as a principal, accountant, attorney,
consultant, shareholder (if the company was a development stage
company when it went public), or promoter; (2) specify for each
such
entity the nature and extent of the principal`s or affiliate`s
involvement; (3) indicate for each such entity whether or not a
principal or affiliate of either a principal or the company was in
any way involved in an offering of securities by such entity and
if
so describe in reasonable detail the extent and nature of such
involvement; (4) for each such entity whether or not such entity
is
or was subject to Rule 419 or otherwise qualifies or qualified as
a
"blank check" company; (5) for each such entity whether or not
such
entity was involved in any merger transaction, including but not
limited to a "reverse merger" transaction as well as any
principal`s
or affiliate`s role in such transaction(s); and (6) whether any
principal or any affiliate of either a principal or the company
has
ever acted as a broker or dealer in any transaction, and if so
describe such activities.  We may have further comment.

3. We note your disclosure on page 8 that "as of the date of the
registration statement the company has not entered into
negotiations
or agreements preliminary or otherwise with respect to any
potential
acquisitions."  Revise your disclosure to indicate whether the
company will to enter into a merger or acquisition with a non
mining
entity.

Business

4. Please revise to provide the disclosure required by Item 101(a)
of
Regulation S-B.  We note that the company was managed by Keith
Ebert,
then Gerald Tuskey and finally by Gerald Shields and Leonard
MacMillan.  Specifically address the ownership of the company
since
formation.

Plan of Operation, page 9

5. We note your statement that we expect to acquire additional
mineral exploration prospects over the next 12 months.  Indicate
the
amount of funds that you will allocate to acquire these additional
exploration prospects.

6. We note that your phase two exploration program is scheduled
for
completion before the end of June 2005.   As required by Item
303(a)
revise your disclosure to describe your plan of operations for the
next twelve months.  We may have further comment.

Security Ownership of Certain Beneficial Owners and Management,
page
20

7. Please provide a detailed analysis as to why Mr. Tuskey should
not
be considered a promoter based on his activities undertaken in
connection with the company.  We note your disclosure with respect
to
the dates of Mr. Tuskey`s directorship, the activities carried out
by
the company during such time, along with your disclosure that
Messrs.
Shields and MacMillan may be defined as promoters of the company
based on their initiative in organizing and developing the
business
of the company after they succeeded Mr. Tuskey as directors of the
company.  We also note your supplemental conclusory statement that
Mr. Tuskey is not a promoter as defined under Rule 405 of
Regulation
C.

8. Please revise to address the beneficial ownership of Mr. Gerry
Diakow.

Directors, Executive Officers, Promoters and Control Persons, page
21

9. Disclosure of Mr. Shields` directorship with SCS Solar
Computing
Systems Inc. should be placed back into the registration
statement.
We also reissue our prior comment 37.  Please disclose the
beginning
date of Mr. Shields` directorship with SCS Solar Computing Systems
Inc. and the nature of its business.

10. Please revise to clarify the type of management consulting
services provided by Resource Management Associates.

11. Indicate the principal business conducted by Trilogy Minerals,
Inc.

12. We note your statement that Leonard MacMillan is the managing
director of Resource Management Associates in Vancouver, British
Columbia.  We also note that you indicate that Leonard MacMillan
resides in San Diego, California.  Supplementally advise us how
MacMillan manages Resource Management Associates in Vancouver,
British Columbia when he resides in San Diego, California.

Description of Securities, page 24

13. We note your response to comment 42 and your statement that
"our
shares ... may be issued only as fully paid and non-assessable
shares."  Your prior statement that all of the current outstanding
common shares are "fully paid and non-assessable" is a legal
conclusion that the company is not qualified to make.  If you want
to
make the statement that the common shares are "fully paid and non-
assessable" then you must attribute this statement to counsel and
file counsel`s consent to be named in this section.  Additionally,
if
you want to retain the statement that your shares may be issued
only
as fully paid and non-assessable shares then attribute the
statement
to counsel and file counsel`s consent to be named in the section.
Please revise as appropriate.

Part II

Market Price of and Dividends on the Registrant`s Common Equity
and
Related Stockholder Matters, page 24

14. Please reconcile the following two statements:
* "None of our issued and outstanding common stock is eligible for
sale pursuant to Rule 144 under the Securities Act of 1933." and
* " As of the date of this registration statement, persons who are
our affiliates hold 3,055,600 shares that may be sold pursuant to
Rule 144 after two years from the date of purchase."

15. Additionally, it appears that the second sentence in your
discussion of Rule 144 relates not simply to any person, but to
affiliated persons.

16. We reissue our prior comment 44.  Please confirm there are no
securities authorized for issuance under equity compensation
plans.

Recent Sales of Unregistered Securities, page 22

17. We reissue our prior comment 46.  Please 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.

18. We note you indicate that the company issued all of its
9,902,300
shares on March 31, 2004.  We also note that the company was
incorporated on February 16, 2004 and that the company conducted
business since March 2003.  Supplementally provide us with a legal
analysis under Nevada law as to how the company conducted business
prior to the company issuing shares on March 31, 2004.  We may
have
further comment.

Financial Statements

19. We note your statement in Note 1 to the financial statements
for
the period ended December 31, 2004 that the financial statements
"should be read in conjunction with the Company`s financial
statements for the fiscal period ended March 31, 2004 included in
the
annual report previously filed on Form 10-KSB."  We do not
understand
your statement given the company has not filed a Form 10-KSB.
Revise
as appropriate.

Form 10-QSB for the quarter ended December 31, 2004

20. Revise your Form 10-QSB for the comments above as applicable.

Exhibits

21. We note the introductory paragraph in your Section 302
certifications that "[i]n connection with the accompanying
Quarterly
Report on Form 10-QSB ... the undersigned, in the capacity and
date
indicated below, hereby certifies that...."  Revise both of your
certifications to delete your introductory paragraph and provide
the
certification as exactly as set forth to include "I, [identify the
certifying individual], certify that ...."

Closing Comments

       As appropriate, please amend your registration statement
along
with your 1934 Act filing and respond to these comments within 10
business days or tell us when you will provide us with a response.
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 supplemental 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.

      You may contact Maureen Bauer at (202) 942-1824 if you have
questions regarding comments on the financial statements and
related
matters.  Questions on other disclosure issues may be directed to
John Zitko at (202) 824-5532, or to David Link, who supervised the
review of your filing, at (202) 942-2999.

				Sincerely,

				John Reynolds, Assistant Director
				Office of Emerging Growth Companies

cc: 	Gerald Tuskey, Esq.
	Fax (604) 688-4933
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Trend Technology Corporation
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