SecProbe.io

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                      Interactive Television Networks, Inc.
                           28202 Cabot Road, Suite 300
                             Laguna Niguel, CA 92677

October 12, 2005

Via EDGAR

Securities and Exchange Commission
Division of Corporate Finance
Office of Small Business Review
450 Fifth Street, N.W.
Washington, D.C.  20549

Attn: Larry Spirgel, Assistant Director

         Re:  Interactive Television Networks, Inc. (the "Company")
              File No. 000-50122

Dear Mr. Spirgel:

      By letter dated  September 27, 2005 (received by the Company on October 3,
2005),  the  staff of the  Securities  and  Exchange  Commission  (the  "Staff")
provided this Company,  Interactive Television Networks,  Inc., with comments to
this  Company's  Quarterly  Report on Form 10-QSB for the period  ended June 30,
2005. This letter contains our responses to the Staff's comments. The numbers of
the  responses  and the  headings  set forth below  correspond  to the  numbered
comments and headings in the September 27, 2005 letter from the Staff.

Form 10-QSB for the quarterly period ended June 30, 2005

Consolidated Statements of Operations, page 4
1. As stated in note 4 to the Form 10-QSB,  the Company has capitalized  certain
set-top  boxes which were  provided to a limited  number of initial  subscribers
free of charge. The costs of such boxes were absorbed by the Company. Said boxes
are being  depreciated over their useful lives and such depreciation is included
in cost of goods  sold.  Future  filings  will state that such  depreciation  is
included in cost of goods sold.

Hardware Revenues, page 7
2. Revenue is recognized  upon the shipment of set-top boxes in accordance  with
GAAP since the customer is paying for shipment and the risk of loss transfers to
the customer at the time of shipment.

3. In regards to EITF 00-21,  the set-top box and the monthly  service  revenues
are considered to be multiple deliverables as 1) the delivered item, the set-top
box, has value to the customer on a stand-alone  basis, since it could be resold
to a third party; 2) there is objective and reliable  evidence of the fair value
of the undelivered item and the monthly subscription is the same if the customer
purchases a set-top box or is loaned a set-top  box;  and 3) there is no general
right of return.  Accordingly,  the set-top box and the monthly subscription are
considered separate accounting units and revenue is recognized  accordingly,  as
stated in Note 2 to the 10-QSB

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                                   * * * * *

      As requested by the Staff, we hereby acknowledge that:

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

o     Staff  comments or changes to disclosure in response to staff  comments do
      not  foreclose the  Commission  from taking any action with respect to the
      filing; and

o     This 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.

      Please direct questions  regarding this letter to the undersigned at (949)
365-5655.

                                            Very truly yours,

                                            Murray Williams
                                            Chief Financial Officer

Cc:    Istvan Benko, Esq.
       Michael Henderson
       Kyle Moffatt

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