SecProbe.io

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March 22, 2005

Via facsimile and U.S. Mail

Graham Taylor
President, CEO, CFO, Secretary,
Treasurer and Director
1285 West Pender Street
Suite 110
Vancouver, A1 V6E 4B1

            RE:        Magnus International Resources, Inc.
                          Form 10-KSB for the fiscal year ended
July
31, 2004
                           File number 000-49961

Dear Mr. Taylor:

      We have reviewed the above filing and have the following
accounting 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 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.

Form 10-KSB for the fiscal year ended July 31, 2004

Description of Properties, Page 10

		The Boka Trend Discovery, Page 12

1. We note your statement regarding the findings on one of the
first
tunnels to be sampled by Southwestern Resources Corporation and
Team
209 at the Boka Trend. We also note your statement referencing
gold
reserve estimates made by Raymond James Financial. Such statements
should not be included in your filings unless they can be
supported
by reserve reports. Please supplementally provide the reserve
reports
or remove the statements from your future filings.

Controls and Procedures, Page 21

2. We note your statement that the company "believes that it
maintains proper procedures for gathering, analyzing and
disclosing
all information in a timely fashion that is required to be
disclosed
in its reports under the Securities Exchange Act of 1934, as
amended." Please revise your statement to reflect the following:
A. It does not appear that your certifying officers have reached a
conclusion that your disclosure controls and procedures are
effective.  Please revise to address your officers` conclusions
regarding the effectiveness of your disclosure controls and
procedures. Please refer to paragraph (a) of Item 307 of
Regulation
S-K.
B. Revise to clarify, if true, that your officers concluded that
your
disclosure controls and procedures are also effective to ensure
that
information required to be disclosed in the reports that you file
or
submit under the Exchange Act is accumulated and communicated to
your
management to allow timely decisions regarding required
disclosure.
Please refer to Exchange Act Rule 13a-15(e).

3. Please note that paragraph (a) of Item 307 requires an
evaluation
of the disclosure controls and procedures to be performed "as of
the
end of the period" covered by the quarterly or annual report,
rather
than "as of a date within 90 days of the filing date" of the
quarter
or annual report.  In the future, please perform the evaluation as
of
the end of the period covered by the quarterly or annual report,
and
revise your disclosure accordingly.

Directors, Executive Officers, Promoters and Control Persons;
Compliance with Section 16(a) of the Exchange Act, Page 21

	Current Directors and Executive Officers, Page 21

4. The directors` age and bio information detailed in your
disclosure
appears inaccurate. Based on your disclosure, it appears that Mark
Demmons and Raymond Turner, who are listed as 31 and 30 years old,
respectively, have each started their career at an age as early as
11
years old.  Please review your disclosure and confirm to us that
the
age and bio information as presented is accurate or revise as
necessary.

Financial Statements, Page F-1

5. We note that your consolidated financial statements as of and
for
the year ended July 31, 2003 were audited by other auditors. Your
consolidated financial statements must be accompanied by the
predecessor auditors` audit report.  Please ensure that the
predecessor auditors` audit report is included in the Form 10-KSB.

6. We note that your auditors are located in Vancouver, Canada.
It
appears that a significant portion of your assets, liabilities,
and
business activities relate to operations located in China.  Please
briefly tell us how the audit of the operations in China,
including
the associated assets and liabilities, was conducted.  Include a
statement as to whether another auditor was involved in the audit
of
these operations and, if so, the name of the firm.  Also, tell us
the
percentage of your total assets, liabilities, and expenses that
relate to the operations located in China for each period
presented.

Furthermore, we note that in accordance with Article 2 of
Regulation
S-X, we generally believe that the audit report of a registrant
(that
is not a foreign private issuer) should ordinarily be rendered by
an
auditor licensed in the United States.  In light of the fact that
you
are a domestic registrant and that the majority of your operations
are in China, it is unclear how you concluded that it is
appropriate
to have an audit report issued by an auditor licensed in Canada.
Further guidance may be found in Section 5.K of "International
Reporting and Disclosure Issues in the Division of Corporation
Finance" on the Commission`s website at:
http://www.sec.gov/divisions/corpfin/internatl/
cfirdissues1104.htm.
Please tell us how you concluded it is appropriate to have an
audit
report issued by an auditor licensed outside of the United States.

Exhibit 31.1

7. Your reference to the Exchange Act Rules is incorrect.  Please
revise your reference to the Exchange Act Rules to state "13a-
15(e)
and 15d-15(e)".

8. Please be advised that the paragraph 4(b) in your
certification,
the paragraph certifying the design of internal control over
financial reporting, need not be provided until the first annual
report required to contain management`s report on internal control
over financial reporting. Unless you have completed an evaluation
of
internal control over financial reporting (under Section 404 of
the
Sarbanes-Oxley Act of 2002), please remove the certification
language
over internal controls in future filings.

Exhibit 32.1

9. In your future filings, please ensure that your certification
is
currently dated.

Closing Comments

      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 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 urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the 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 filings;

* 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 filings.

	You may contact Yong Choi, Staff Accountant at (202) 824-5682
or
Kim Calder, Assistant Chief Accountant at (202) 942-1879 if you
have
questions regarding comments on the financial statements and
related
matters.  Direct any other questions to the undersigned at (202)
942-
1870.

Sincerely,

H. Roger Schwall

Assistant Director
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Magnus International Resources, Inc.
March 22, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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