SecProbe.io

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      January 24, 2005

Mail Stop 0408

By U.S. Mail and facsimile to +1 (607) 925-9613

Mr. Brian C. Doutaz
President and Chief Executive Officer
Alton Ventures, Inc.
12880 Railway Avenue - Unit 35
Richmond, British Columbia V7E 6G4
CANADA

Re:	Alton Ventures, Inc.
	Amendment Number Four to Form SB-2 filed January 10, 2004
	File No. 333-118077

Dear Mr. Doutaz:

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

      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.

Named Experts and Counsel - page 28

1. Regarding your statement that your unaudited interim financial
statements have been reviewed by your independent public
accountants,
please revise your registration statement as follows:
* Include the report of your independent public accountants with
respect to their review of your unaudited interim financial; and
* File as an exhibit a letter from your independent public
accountants which acknowledges awareness of the use of their
report.
Refer to Article 10-02 (d) of Regulation S-X. Alternatively,
remove
the statement that the unaudited interim financial statements have
been reviewed by your independent public accountants.

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  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 a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as 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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
acceleration of a registration statement.  Please allow adequate
time
after the filing of any amendment for further review before
submitting a request for acceleration.  Please provide this
request
at least two business days in advance of the requested effective
date.

      You may contact Heidi Smetzer at (202) 824-5463 or Donald A.
Walker at (202) 942-1799 if you have questions regarding comments
on
the financial statements and related matters.  Please contact
Timothy
Geishecker at (202) 824-5301 or me at (202) 942-1760 with any
other
questions.

						Sincerely,

						Donald A. Walker
						Senior Assistant Chief Accountant

cc:	Brian McDonald, Esq.
	5781 Cranley Drive
	West Vancouver, British Columbia V7W 1T1
	CANADA

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Mr. Brian C. Doutaz
Alton Ventures, Inc.
Page 3 of 3

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