SecProbe.io

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(Letter head)

March  11,  2005

United  States  Securities  and  Exchange  Commission
Washington,  D.C.
20549

Mail  Stop  4-6

ATTENTION:  MR. MARK P. SHUMAN

Dear Mr. Shuman:

In  response to your staff's letter dated January 26, 2005, I have the following
responses.

GENERAL
-------

1.   The  financial statements, included in our Form SB-2A, have been updated to
     November 30, 2004 as per the requirements of Rule 310(g) of Regulation S-B.

2.   This issue will be sold to subscribers outside the United States. This fact
     has  been stated on page 19 under Item 8 - Plan of Distribution as follows:

"The  Company will be selling the shares through this offering only to investors
in  British  Columbia.   Sales  will  be  made  in  accordance  with the British
Columbia  securities  laws".

PROSPECTUS  SUMMARY,  PAGE  1
-----------------------------

3.   The  previous  section  relating  to  proven and probable reserves has been
     eliminated and has been included under "Lack of Viable Mineral Reserves" on
     page  33.

(Address)

                                      -1-
<PAGE>

     The  second  sentence  in  the new third paragraph consisting of "The claim
consists of approximately 1,235 acres" has been eliminated since it mentioned on
page  33  under  the  heading  "Claim  status".

     The  third  sentence  in  the  new  third  paragraph has been eliminated as
follows:  "It  is 80 miles northeast of Vancouver, British Columbia' since it is
mentioned  on  page  32  under  "Property  Description,  Location  and  Access".

     The  former  paragraph  starting  with "The Company has had no revenues and
very  limited  losses  of  $120,029" has been eliminated due to this information
being  elsewhere  in  the  prospectus  and  under  the  "Summary  of  Financial
Information"  in  this  section.

4.   The Prospectus Summary has been changed to include the headings of "History
     of  the  Company",  "Business",  "Offering"  and  "Use  of  Proceeds".

     The last sentence in the above noted eliminated paragraph has been moved to
the  section  under  "Summary  of  Financial  Information"  since  it is felt an
investor  would want to know this information prior to considering an investment
in  our  company.

     Offering

Under  "Offering',  the  following  sentence  has  been  inserted  as  follows:

"There  is  no minimum amount required to be raised by the Company and hence the
Company  can  use  all  the  proceeds  from  investors  immediately."

Even  though  this  sentence  was not originally included it is felt an investor
would  want  to  know  this  fact  prior  to  making  an  investment.

Other  adjustments  to  Prospectus  Summary

                                      -2-
<PAGE>

The  previous  sentence  in  the  seventh  paragraph  which  states "The Company
anticipates minimum operating  .Plan of Operations)" has been transferred to the
section  under  the  Summary  of  Financial  Information.

The  previous  last  paragraph starting with "It will take many years to explore
.funds  to  achieve  such  a  program"  has  been eliminated due to being stated
elsewhere  in  this  Summary.

5.     In  response  to  this  comment the following paragraph has been inserted
under  the  Summary  of  Financial  Information.

     "The  Company's  independent  accountants  have  indicated in their opinion
dated November 5, 2004 that the Company will need additional working capital for
its  planned  activity  and  to service its debt, which raises substantial doubt
about its ability to continue as a going concern.  If the Company does not raise
sufficient funds from this Offering to meet its debt obligations and to maintain
the  Tylerstone  in good standing, there is the distinct possibility the Company
will  not be able to operate as a going concern and any investor subscribing for
shares  under  this  Offering  will  lose  their  entire  investment".

SUMMARY  INFORMATION  OF  THE  COMPANY,  PAGE  1
------------------------------------------------

6.     The  sentence  in  question  has  been  changed  to  read  as  follows:

     "There  is  no  assurance  that the Company will find a commercially viable
mineral reserve on the Tylerstone regardless of the dollars spent on exploration
work  on  it.  Therefore,  no  matter how much exploration work is undertaken, a
commercially  viable  mineral  reserve  might  never  be  found.'

                                      -3-
<PAGE>

SUMMARY  FINANCIAL  INFORMATION,  PAGE  2
-----------------------------------------

7.     The  error  has  been  noted and the Summary of Financial Information has
been  updated to November 30, 2004 with comparisons as at August 31, 2004.   The
current  figures agree with the interim and annual financial statements included
in  the  prospectus.

RISK  FACTORS,  PAGE  3
-----------------------

8.     In  response to this comment the following Risk Factor headings have been
changed:

Risk  Factor  No.1  on  page  3

The  heading  of  this  Risk  Factor  has  been  changed  to  read  as  follows:

     "Loss  of  Total  Investment  by  New Investors if the Company is Unable to
Raise  Sufficient  Funds  to  Carry  on  Operations"

Risk  Factor  No.  4  on  page  4

     The  heading  of  this  Risk  Factor  has  been changed to read as follows:

     "The  Directors and Officers are self-underwriting this offering which will
result  in  no  independent  evaluation  of  the  offering  price  paid  by  new
investors".

Risk  Factor  No.  10  on  page  9

The  heading  of  this  Risk  Factor  has  been  changed  to  read  as  follows:

     "The  Company  has only one mineral claim which might impair its ability to
attract  capital  to  acquire  further  mineral  properties."

9.     The  previous  paragraph  on  page  3  directly under the heading of Risk
Factors  has  been  deleted since this information has been disclosed under Risk

                                      -4-
<PAGE>

Factor  10  on  page  5.

10.     In  response  to  this  comment  the  entire previous paragraph under C.
Management and the Company; Risk Factor No. 1 on page 9 has been changed to read
as  follows:

     "The  Company expects to face many of the new challenges in the start-up of
its  business.  First, the Company will be required to raise capital to complete
its  exploration programs on the Tylerstone claim and provide sufficient working
capital  to  enable it to continue as a going concern.   Second, it will have to
undertake  exploration programs to determine whether the Tylerstone actually has
a  viable  ore  reserve  thereon  and  if  not  to evaluate the possibilities of
identifying  other  mineral  claims  of  merit.  Third,  it will have to attract
individuals  who have knowledge in exploration and in assisting the directors to
develop  the Company in the direction as set forth elsewhere in this prospectus;
that  of  becoming a mineral exploration company.  Fourth, the Company will have
to  meet  all the standards and requirements of a company seeking a quotation on
NASD.  Fifth,  it  will  have to meet all the requirements of communicating on a
regular  basis  with  its shareholders and in maintaining its status as a public
quoted  company.

If  the  Company  does not address all or any of the above challenges associated
with  the  starting  up  of  a  new  business  enterprise, there is the distinct
possibility it will not succeed and will eventually cease operation resulting in
the  total  loss  of  their  investments  by  the  new  investors."

     The  paragraph  under  Risk  Factor  2  under  Section C on page 9 has been
re-written  as  follows:

     "The  Company commenced business operations on September 24, 1998 and since
that  date  has  incurred  accumulated  losses of $128,089 without realizing any
revenue from any source.   In addition, management has estimated during the next

                                      -5-
<PAGE>

twelve  months  its  cash  requirements will be $33,775 which would result in an
accumulated  deficit  of  $161,864 due to outlays of cash being expense related.
Even  if  the  Company  is  able to raise the maximum amount of money under this
offering, being $300,000, it will not reduce the accumulated deficit since these
funds will be applied to Phases I to III of the exploration programs which total
$247,500.  By spending these funds on the exploration programs, it will have the
effect  of  increasing  the  accumulated  deficit to $409,364.  Only through the
accumulation  of  net  profits  would the deficit be reduced.  Net profits might
never  occur."

Risk  Factor  No.  6  on  page  10  has  been  changed  to  read  as  follows:

     MESSRS.  STEPHENSON  AND  SKODA  ARE  THE  ONLY  DIRECTORS WHO HAVE HAD ANY
EXPLORATION  EXPERIENCE  SINCE  BOTH  MS.  MURPHY  AND  MR.  HAWKINS HAVE HAD NO
INVOLVEMENT  IN  THE  PAST  WITH  AN  EXPLORATION  COMPANY

     "Laurence Stephenson, President, and Edward Skoda, Director of the Company,
have  experience  in the exploration industry but neither Louise Murphy nor Fred
Hawkins have ever been involved in an exploration company.  Louise Murphy's back
ground  is  in  accounting and administration of professional firms whereas Fred
Hawkins  has been in construction industry for the majority of his working life.
In  the event, Messrs. Stephenson and Skoda were unable to assist the Company in
its  exploration  activities  due  to  terminating  their  involvement  with the
Company,  neither  Louise  Murphy  nor  Fred  Hawkins  would have the experience
necessary to manage an exploration program on the Tylerstone claim.   Therefore,
consultants  would  have  to be hired to assist in the exploration activities on
the Tylerstone and to make the decisions as to further exploration work thereon.
The  Board  of  Directors would not have an individual whom had knowledge of the
exploration  industry and could advise it as to the future approach to be taken.

                                      -6-
<PAGE>

Bearing  this  in mind, a new investor may not wish to invest in a company where
the Board of Directors comprised members who are unfamiliar with the exploration
industry."

11.     Risk Factor 11 on page 6 has been changed to reflect a change of control
after  the  offering  as  follows:

"THE ISSUANCE OF SHARES UNDER THIS OFFERING MIGHT RESULT IN A CHANGE OF CONTROL"

     "Before  this  Offering,  the  Directors  and  Officers control 57 % of the
issued and outstanding shares.   If only 500,000 shares are subscribed for under
this  Offering,  the percentage ownership by the Directors and Officers would be
reduced to 46 % thereby resulting in the possibility of a change in control.  If
the  entire  Offering is subscribed for, the ownership percentage of the current
Directors  and  Officers  would  be  reduced to 23 % which would enable one or a
group  of  shareholders,  acting  together,  to  accumulate sufficient shares to
change  the  Board of Directors and therefore control.  New investors might want
to  give  consideration  to  the  possibility of a change in control which might
result  in  individuals  being  elected to the Board of Directors whom these new
investors, under normal circumstances, would not have entrusted with their money
and  the  operation  of  the  Company."

12.     During  the  exploration  stage, comprising Phases I to III, the Company
does  not  wish  to  bear the cost of verifying the boundaries of the Tylerstone
claim  by survey.   It would only become practical to undertake a survey if, and
only  if,  an  ore  reserve  of  merit  were  found  on  the  Tylerstone  claim.
Therefore,  under  Section  B - Exploration of the Tylerstone, Risk Factor No. 5
has  had  the  following  sentence  added  therein:

     "The  Company will not verify the boundaries of the Tylerstone by survey in
the  near  future  and  might  never  undertake  a  survey."

                                      -7-
<PAGE>

13.     In  response  to  this  comment, a new sentence has been inserted in the
paragraph  on  page  8  as  follows:

     "If  the crew had to carry the supplies it might prove difficult to attract
an  exploration  crew  -  refer  to  "Hiring  an  Exploration Crew" on page 31".

The  above  mentioned  paragraph  on  page  31  reads  as  follows:

     Due  to the hardship of the Tylerstone in accessing it by foot, the Company
might  find  it  difficult to hire an exploration crew when it is needed. In the
event  the  Company  does  not  wish  to  incur the cost of using helicopters to
transport  the  crew  and  supplies  to the Tylerstone, only certain exploration
workers  would  be  suitable to climb the wooded mountain side to the Tylerstone
while  packing  in supplies and tent facilities. These individuals would have to
be  in  good  physical shape and willing to endure hardships in traveling to and
from  the  Tylerstone.  This  fact will limit the number of available men in the
town of Gold Bridge which would result in the Company having to seek exploration
workers  in  other  areas of British Columbia. There is the distinct possibility
the  Company  would  have  to  pay  above  normal  wages for these workers to be
convinced  to  explore  the  Tylerstone.  This  being  the  case, it will have a
financial  impact  on  the  Company since its costs associated with hiring these
exploration  workers  would  substantially  increase.

14.     In  response to this comment, the previous paragraph has been amended on
page  10  as  follows:

     "WITHOUT  FUNDS  FROM  THIS  OFFERING,  THE  COMPANY  WILL  NOT  BE ABLE TO
UNDERTAKE ANY EXPLORATION ON THE TYLERSTONE AND WOULD NOT BE ABLE TO CONTINUE AS
A  GOING  CONCERN."

     "Currently,  the  Company  has  no  operating capital and is relying on the
proceeds  from  this  Offering  to  complete  Phases I to III of its exploration
programs,  at  a  cost  of $247,500, and to contribute funds to pay the Offering

                                      -8-
<PAGE>

expenses  of  $26,100  and  partial  payment  to  third parties.  Management has
estimated  $7,675,  not  including  $26,100  for  Offering  expenses,  for  cash
requirements  over  the  next  year plus $47,718 owed to third parties; refer to
page  13.  Since  there  is  no minimum amount of shares that must be sold under
this  Offering,  the  Company  may not have sufficient funds to proceed into the
future.  There  are  no  other  sources  of  funds  at this time other than this
Offering  unless  the  Directors and Officers are prepared to personally advance
funds  to  the Company or guarantee a loan from a financial institution.  At the
present  time,  the  Directors  and Officers are not considering either of these
solutions.  Without  new  investors  subscribing  to this Offering, there is the
distinct  possibility  the Company will cease as a going concern within the next
twelve  months,  Any new investor should give careful consideration to this fact
prior  to  making  an  investment  in  the  Company."

     The  prior  reference to the market price of gold, silver, lead or zinc has
been  deleted  in the above paragraph since it might lead an investor to believe
that the Company will be able to produce these minerals which might never be the
case.

15.     The  Company has paid cash sufficient to maintain the Tylerstone in good
standing  until  February  24,  2006.  Therefore, Section B - Exploration of the
Tylerstone  ona  page 6, a new Risk Factor No. 1 has been inserted as follows in
response  to  this  comment:

     "THE  TYLERSTONE  IS IN GOOD STANDING WITH THE MINISTRY OF ENERGY AND MINES
UNTIL  FEBRUARY  24,  2006 AT WHICH TIME FURTHER ASSESSMENT WORK WILL HAVE TO BE
DONE

     The  Tylerstone  claim is in good standing until February 24, 2006 at which
time  assessment  work  or cash in lieu of assessment work will have to be filed
with  the  Mini