SecProbe.io

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Mail Stop 3561
								December 30, 2005
Mr. Shailen Singh
Chief Executive Officer
Coffee Pacifica, Inc.
8726 Barnard Street
Vancouver, BC  V6P 6A6
Canada

      Re:	Coffee Pacifica, Inc.
Form 10-KSB for the Fiscal Year Ended December 31, 2004
		File No. 333-101702

Dear Mr. Singh:

      We have reviewed your filing and have the following
comments.
We have limited our review to your financial statements and
related
disclosures and do not intend to expand our review to other
portions
of your document.  Where indicated, we think you should revise
your
disclosures 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
explanations.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may 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 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 December 31, 2004

Market for Common Equity and Related Stockholders Matters

1. Please amend your filing to include the information regarding
your
securities authorized for issuance under equity compensation
plans.
Refer to Item 201(d) of Regulation S-B.

Report of Independent Registered Public Accounting Firm

2. We advise you that since you are a development stage
enterprise,
your statements of stockholders` equity, operations and cash flows
for the period since your inception through December 31, 2004 must
be
audited.  Please have your current auditors provide a revised
audit
report in an amendment to your Form 10-KSB once they have audited
these financial statements.

3. We note the reference in your auditors` opinion to the
predecessor
auditors` opinion over the financial statements as of and for the
year ended December 31, 2003 and the cumulative data from
inception
(December 21, 2001) to December 31, 2003.  Please obtain and file
your prior auditors` report covering the December 31, 2003
statement
of operations, cash flows and statement of stockholders` equity
and
the cumulative data from inception (December 21, 2001) to December
31, 2003 in an amendment to your 2004 10-KSB.

Controls and Procedures

4. Please amend your filing to indicate whether your disclosure
controls and procedures are effective as of the end of the period
covered by this report (not within 90 days of the filing date.)
Also
disclose any change in your internal control over financial
reporting
that occurred during your last fiscal quarter (fourth fiscal
quarter
in the case of an annual report) that has materially affected, or
is
reasonably likely to materially affect your internal control over
financial reporting.  Refer to Items 307 and 308(c) of Regulation
S-B
and SEC Release No. 33-8238.

Exhibits

Consents of Experts

5. It appears that you have not filed the consent from your
independent accountants to incorporate by reference your financial
statements into your previously filed registration statements.
Please amend your filing to include the consent as exhibit 23.
Refer
to Item 601(b)(23) of Regulation S-B.

Exhibit 31

6. Please revise your filing so that your certifications read
exactly
as set forth in Item 601(b)(31) of Regulation S-B.   Specifically,
the wording and Exchange Act Rule references in item 4 are
incorrect.
Also, the items disclosed in your item 6 should be part of item 4,
as
there is no item 6 in the certification.

* * * * *

       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
that keys your responses to our comments and provides any
requested
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 filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	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 filing;

* 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

* 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 filing or in
response to our comments on your filing.

	You may contact Scott Ruggiero at (202) 551-3331 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3716 with any other
questions.

Sincerely,

William Choi
Branch Chief
Mr. Shailen Singh
Coffee Pacifica, Inc.
December 30, 2005
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