SecProbe.io

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MAIL STOP 0511

	May 25, 2005

Gerald J. Shields
President
Trend Technology Corporation
Suite 1020
510 Burrard Street
Vancouver, British Columbia
V6C 3A8 Canada

RE:	Trend Technology Corporation
	Amendment No. 2 to Registration Statement on Form 10-SB12G
	Filed on April 19, 2005
	File No. 000-50978

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. We reissue our prior comment 2 and request not only a complete
response to all items within the comment but, also, when providing
the names of issuers that have undergone a merger transaction, you
do
so consistently between the listed individuals (i.e., if you list
an
entity by its post-merger name under one individual, do not list
that
same entity under its pre-merger name for another individual).

Please 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.

2. We reissue our prior comment 3.  Revise your disclosure to
indicate whether the company will to enter into a merger or
acquisition with a non mining entity.

Business, page 3

3. We reissue our prior comment 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.

Security Ownership of Certain Beneficial Owners and Management,
page
20

4. Revise the number indicated in the group of officers and
directors
as appropriate.

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

5. We note the statements that "OSI is the pioneer in the geo-
spatial
intelligence and the world leading fleet supplier of electronic
chart
systems for navigation and situational awareness in NATO and
allied
markets."  Please note that the reasonable basis for comparative
factual assertions and for your beliefs in certain qualitative
statements must be clear from the text of the offering statement.
If
not already disclosed, please summarize the support for each such
promotional statement in your prospectus.  If your support comes
from
third parties, please name them in the offering statement and file
as
exhibits their consents to being named in the offering statement
and
to the summary of their reports.  If you cannot provide us with
the
reasonable basis for these assertions, you should delete them.

6. We note your response to our prior comment 12, wherein you
state
"Mr. MacMillan maintains residences in San Deigo and Vancouver.
He
currently resides in Vancouver."  The address you have provided
for
Mr. MacMillan appears to be a branch of "Mailboxes, Etc."  If
true,
please disclose that such address is located at Mailboxes, Etc."

Certain Relationships and Related Transactions, page 23

7. Please revise to address the number of shares purchased by
Gerald
Tuskey and the consideration given for those shares.  Also reflect
the consideration on a per share basis.  Provide any other
disclosure
required by Item 404(d) of Regulation S-B.

Part II

Recent Sales of Unregistered Securities, page 22

8. Contrary to the assertion contained in your letter of April 18,
2005, our prior comment 18 was not issued in error.  You are
correct
in noting that the company`s date of incorporation was incorrectly
stated, but such incorrect reference did not affect the question
we
raised, which appears to have been left unanswered.  We therefore
reissue our prior comment in amended form:

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, 2001 and has 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.

9. We note your statement that "the subscribers confirmed in
writing
and represented to us that they were accredited investors ...."
Revise the disclosure to clarify that the company made the
determination that each purchaser was an accredited investor.

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) 551-3237 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) 551-3399, or to David Link, who supervised the
review of your filing, at (202) 551-3790.

				Sincerely,

	John Reynolds
	Assistant Director

cc: 	Gerald Tuskey, Esq.
	Fax (604) 688-4933
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Gerald J. Shields
Trend Technology Corporation
May 25, 2005
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