SecProbe.io

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      Mail Stop 4561
									September 29, 2005

Mr. Steve S. Sinohui
President
SIN Holdings, Inc.
3225 S. Garrison
Unit 21
Lakewood, Colorado   80227

      Re:	SIN Holdings, Inc.
		Form 10-KSB for Fiscal Year ended December 31, 2004
		Filed March 16, 2005
      File No. 000-49752

Dear Mr. Sinohui:

      We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise your documents 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
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.

Form 10-KSB for the year ended December 31, 2004

Item 6 - Management`s Discussion and Analysis Financial Condition
and
Results of Operations

Liquidity and Capital Resources, page 9

1. We note that you have incurred operating losses since
inception,
lack the financial resources to repay your debt obligations as
they
come due and are unable to meet other current and anticipated
future
cash requirements without additional funding from your principal
shareholder.  Please advise us of any contractual obligations of
Desert Bloom Investments, Inc. to provide you with operational
funding.  In the absence of a contractual commitment from Desert
Bloom Investments, there is substantial doubt about your ability
to
continue as a going concern.  In that regard, please advise us why
your auditors have not included an explanatory paragraph regarding
the substantial doubt about your company`s ability to continue as
a
going concern in their audit report.  Likewise, please revise your
footnotes as necessary to include disclosure regarding the
pertinent
conditions and events giving rise to the substantial doubt, the
possible effects of the conditions, management`s evaluation of the
significance of the conditions and any mitigating factors,
possible
discontinuance of operations, and management`s future plans.  For
reference see AU Section 341.

Note A - Summary of Accounting Policies, page F-6

2. We note that you have not recorded any impairment charges on
your
goodwill.  In light of your company`s continued losses and
insufficient cash flows, please tell us how you determined that
the
goodwill amount of $5,071 recorded on your balance sheet is not
impaired.

      As appropriate, please amend your 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 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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes 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 comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filing.

      You may contact Jessica Barberich at (202) 551-3782 or me at
(202) 551-3429 if you have questions regarding comments on the
financial statements and related matters.

								Sincerely,

Kristi Beshears
Staff Accountant

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Mr. Steve S. Sinohui
SIN Holdings, Inc.
September 29, 2005
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