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SIN Holdings, Inc. 12/7/2005 SEC Correspondence

     SIN
Holdings, Inc.
P. O. Box 370912
Denver, Colorado 80237
(303) 763-7527

December 7, 2005

Ms. Jessica Barberich
Staff Accountant
United States Securities and Exchange Commission

100 F St. Street, NE
Washington, DC  20549

     RE:

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

Dear Ms.
Barberich:

Thank
you for your letter dated November 30, 2005. I will respond to your inquiries by
referencing the paragraph numbers from your letter.

     1.

     Our
auditors gave consideration to the following:

     A.

      Recurring
Operating Losses.  Net losses decreased from 2002 to 2004 from $21,979 in 2002 to $10,188
in 2003 to $8,548 in  2004.  This decrease indicated to them that the Company was
controlling costs since the last stock offering in  2002.

     B.

     Working
Capital Deficiencies.  The Company's majority shareholder indicated that some or all of
the loans could be converted  to capital which would result in no deficiency.

     C.

     Negative
Cash Flows from Operating Activities.  Negative cash flows from operating activities
decreased from $11,490 in 2003  to $7,618 in 2004 showing improvement by management and a
trend toward cash flowing from operations rather than  borrowings.

     D.

     Inability
to Repay Debt. While the Company has not been able to repay debt, it  has borrowed less
each year ($20,022 in 2002, $10,500 in 2003 and $5,500 in  2004) and been able to extend
the terms of the majority of the debt. Debt of  $188 that was not extended by lenders was
re-paid. Additionally, the majority  shareholder has indicated that some or all of the
loans can be converted to  capital.

     In
reviewing the Company’s plans and options for mitigating the above conditions, our
auditors concluded that substantial doubt about our inability to continue as a going
concern for a reasonable period of time did not exist. Therefore, they did not modify the
auditors’ report.

     2.

In assessing goodwill for impairment, and pursuant to SFAS 142, we compared the
fair value of the Company to the carrying value, including goodwill, of $5,938.
SFAS 142 states that “if the fair value of a reporting unit exceeds its
carrying amount, goodwill of the reporting unit is considered not
impaired.” When conducting our assessment of fair value, we looked at
comparable web sites that were for sale, including sites that did not have the
volume of traffic that our site had. From January of 2003 to December of 2004,
www.senior-inet.com averaged approximately 50,000 requests per month.

     We
looked at web sites that were considered directory web sites. We looked at the number of
requests these sites received each month, their monthly income and the sales price for
these sites. We researched only fully-developed web sites.

     COMPARABLE WEB SITES FOR SALE

     CATEGORY
     DOMAIN
     DATE SITE
STARTED

# OF
MONTHLY
REQUESTS
     MONTHLY
INCOME
     ASKING
PRICE

     Directory

     vDictionary.com

     Nov-04

     0

     $0

     $2,000

     Directory
     LuckyNumber.net
     Nov-04
     0

     $0

     $2,000

     Directory
     RatedHigh.com
     Sep-04
     0

     $0

     $5,000

     Directory
     phonebooksonline
     Jun-04
     0

     $0

     $70,000

     Directory
     trafficgateway.com
     Mar-04
     50

     $700

     $3,500

     Directory
     loanssurance
     Mar-04
     100

     $1,500

     $25,000

     Directory
     HighStuff
     Dec-04
     400

     $150

     $4,000

     Directory
     entertainusa
     Mar-04
     2,000

     $2,000

     $40,000

     Directory
     DentalSearch.com
     Jun-03
     9,500

     $0

     $68,000

     Directory
     DentalSearch
     Mar-04
     10,000

     $10,000

     $120,000

     Directory
     software directory
     Jan-04
     150,000

     $300

     $20,000

     Senior-inet.com
     May-96
     50,000

     $190

From
this list, we see web sites with no traffic and no income were being sold for
prices between $2,000 and $70,000. Web sites with traffic were being sold for
prices between $3,500 and $120,000. The price per request ranged from $0.13 to
$250. We factored out the upper and lower ends of the range and arrived at an
average price of $23.83 per request. The price per dollar of monthly income
ranged from $5 to $67. We factored out the upper and lower ends of the range and
arrived at an average selling price of $18.33 per dollar of income.

When
we calculated a per request price based on the average of the sites listed above
multiplied by the Company’s average number of requests from January 2003 to
December 2004, we arrived at an asking price of $1.19 million. When we
calculated a price based upon the income to asking price ratio of the sites
listed above, we arrived at a value of $3,500. However, when we simply compared
the Company to the sites in the above chart that most closely resembled the
senior-inet.com site, we arrived at a sales price range of $4,000 to
$20,000. Management believed it reasonable to value the Company’s web site
at approximately $20,000.

Our
valuation of the Company site exceeded the carrying value of the Company.
Therefore, pursuant to SFAS 142, goodwill is considered not impaired and the
second step of the impairment test is unnecessary.

SIN
Holdings, Inc. acknowledges

     •

      that
we are responsible for the adequacy and accuracy of the disclosures in the filing,

     •

that staff comments or changes to disclosure in response to staff comments to
not foreclose the Commission from taking any action with respect to the filings
and

     •

that 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.

Best regards,

/s/ Steve
Sinohui
President