SecProbe.io

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Mail Stop 0306

December 8, 2004

Sebastien Dufort
President
Voyager One, Inc.
859 West End Court, Suite 1
Vernon Hills, Illinois 60061

Re:	Voyager, Inc.
      Amendment No. 1 to Registration Statement on Form SB-2
      Filed November 16, 2004
      File No. 333-118582

Dear Mr. Dufort:

      We have the following comments to your filing.  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.

Prospectus Summary - Page 2
1. We note your response to comment 5.  Please supplementally
provide
us with independent objective support for the industry data
disclosed
in this section.  Please also tell us whether the Photo Marketing
Association and Imerge Consulting Group have each consented to
your
use of the market data you cite in your prospectus and your
associated references to them as the sources of that information
and,
if so, supplementally provide us with copies of those consents.
2. We note your response to comment 8.  Please update the status
of
your product development efforts, including the development "of
the
final form factor product for testing in the fourth quarter."
3. Please clarify the phrases "final form factor," "co-branding"
and
"bundling."

The Offering - Page 3
4. We note your response to comments 10 and 19.  The number of
shares
to be registered for resale must be based on a good faith estimate
of
the number of shares to be issued upon conversion of the
convertible
debentures; it may not simply be based on unsupportable
assumptions
or contractual agreements with investors.  If your good faith
estimate is that the debentures will be convertible based on a
$2.50
closing bid price, then you may only register the number of shares
that would be issuable upon such conversion based on the
prescribed
conversion price formula.  If your good faith estimate is that the
debentures will be convertible based on a lower closing bid price,
then you may also register the additional number of shares that
would
be issuable given that lower price based on the prescribed
conversion
price formula.  Regardless of the amount of your good faith
estimate,
please supplementally provide us with a detailed explanation of
the
basis for that estimate, and please revise so that the disclosures
throughout your prospectus (including, in particular, your
dilution
disclosures and the disclosures in and preceding your selling
stockholders table) are consistent with that estimate.

Shares Acquired in Financing Transaction with Voyager One - Page
16

Convertible Debentures Issued in Connection with Securities
Purchase
Agreement - Page 17
5. We note your revisions to this section and your disclosure
that,
under the terms of the Securities Purchase Agreement, Cornell
Capital
Partners "can purchase up to $1,100,000 in convertible debentures
from Voyager One."  Please further revise your disclosure to
clarify
the nature and extent of Cornell Capital Partners` obligation to
purchase the additional $575,000 in convertible debentures that
have
not yet been issued, including the anticipated timing of those
additional investments.  Please also clarify any circumstances
under
which Cornell Capital Partners would not be obligated to purchase
the
additional debentures.

Trey Resources, Inc. - Page 18
6. We note your disclosure that Trey Resources purchased $550,000
of
the convertible debentures issued under the Securities Purchase
Agreement from Cornell Capital Partners.  We also note, however,
that
only $525,000 worth of convertible debentures appear to have been
issued under the terms of the Securities Purchase Agreement.
Please
revise or advise.

Business - Page 20
7. We note your response to comment 33.  Please tell us what
consideration you have given to including a photograph or a sketch
of
your prototype product in your business section to aid investor
understanding.

Expenses for the three months ended September 30, 2004 - Page 38 &
Expenses for the years ended December 31, 2003 and 2002 - Page 38
8. We note your response to comment 44.  Please expand your
disclosure to describe the nature of all consulting services
provided.  Please also ensure that a summary of the material terms
of
each consulting agreement is included in the prospectus and that
each
consulting agreement is filed as an exhibit to your registration
statement.

Financial Statements

Statements of Operations - page F-17
9. Please consider removing the statements of operations for the
three-month periods ended September 30, 2004 and 2003, since Form
SB-
2 does not require statements for these periods.  If you continue
to
present the statements, you should revise the filing to also
include
a discussion of your results of operations for these periods in
MD&A.

Note 1: Basis for Presentation - page F-20
10. The proposed revisions in response to our previous comment 60
do
not address the intent of the comment.  Paragraph 2.e of SFAS 148
requires specific disclosures in "Summary of Significant
Accounting
Policies" or its equivalent, which in this case is the Basis For
Presentation section.  Please revise to include the information in
the correct section of the filing.

11. In addition, revise this note to disclose the valuation method
being used to determine the fair value of the options on the date
of
issuance.  Disclose the significant assumptions used to estimate
the
fair values. See paragraph 47(d) SFAS 123.

Note 6: Notes Payable - page F-21
12. We note the conversion terms on your 12% notes payable to
Messrs.
Byrne, Culberyon, Didanato, Jassey, Lamb, Mc Grain, and Prikos as
well as the terms of your 6% note payable to Oberman include
conversion rates that will reflect significant discounts from the
market price of your stock on conversion date.
a) Tell us how you will account for the discounts.
b) Explain how you have evaluated the debt issuance for beneficial
conversion features and the guidance in EITF 98-5 and 00-27.
c) Revise this note to address your planned accounting and the
impact
of any charges upon conversion.
Item 26.  Recent Sales of Unregistered Securities
13. We note your response to comment 62.  However, it still does
not
appear that you have included the disclosures required by Item 701
of
Regulation S-B with respect to all sales of unregistered
securities
made during the past three years, including those issuances
reflected
on page F-18.  Please revise as previously requested.

*          *          *

      As appropriate, please amend your registration statement in
response to these comments.  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.

	We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Louis Canant at 202-942-1897 or Brian Cascio
at
202-942-1791 if you have questions regarding comments on the
financial statements and related matters. Please contact Tom Jones
at
(202) 942-1927 or me at (202) 924-7924 with any other questions.

      Sincerely,

							David Ritenour
							Special Counsel

cc (via fax): Philip E. Ruben, Esq.

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Voyager One, Inc.
December 8, 2004
Page 5

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