SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

September 9, 2004

Mail Stop 0405

By U.S. Mail and facsimile to (604) 925-9613.

Brian McDonald, Esq.
5781 Cranley Drive
West Vancouver, British Columbia
Canada V7W 1T1

Re:	The Stallion Group
	Form SB-2 filed August 19, 2004
	File No. 333-118360

Dear Mr. McDonald:

	We have limited our review of this Form SB- 2 to legal issues
relating to the offering 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.

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.

Cover Page
1. Revise to disclose the absolute last day you may sell shares.
Please provide similar disclosure when discussing your plan of
distribution.
2. Revise to disclose that if the minimum is not met, you will
promptly return the proceeds.
3. Revise to disclose the percentage of shares outstanding that are
being registered in this offering and the percentage of shares that
are being offered by selling shareholders.
4. Revise to clarify whether the sale of shares by the selling
shareholders is contingent on the company selling the minimum shares.
Please also disclose whether there are any provisions preventing the
selling shareholders from selling their shares concurrently with your
primary offering.  If there are no restrictions, revise your summary
section disclosure to discuss the impact a concurrent secondary
offering may have on your primary offering.  If appropriate, include
risk factor disclosure.
5. Please disclose that the company has only one executive officer
and director.
6. Revise to disclose that Mr. Williams may purchase shares in order
to meet the minimum number necessary to close the offering.
7. Please disclose whether subscriptions are revocable.

Cautionary Statement Regarding Forward-Looking Statements, page 11
8. Please delete any references to the safe-harbor provisions of the
Private Securities Litigation Reform Act of 1995.  Given your status
as a penny stock, the safe harbor provisions of Section 27A of the
Securities Act and Section 21E of the Exchange Act are not available
because you issue "penny stock" as defined in Exchange Act Rule 3a51-
1.

Dilution of the Price You Pay for Your Shares, page 15
9. In the second paragraph, you state that the per share value prior
to the offering is $0.0040.  However, the table on that page
indicates the per share value prior to the offering to be $0.0045.
Reconcile this inconsistency.
Plan of Distribution, Terms of the Offering
(a) The Offering will be Sold by Our Officers - page 17
10. Revise the title to this section to disclose that you only have
one executive officer.

Selling Shareholders - page 19
11. Revise to indicate whether any of the selling security holders
are broker-dealers or affiliates of broker-dealers.

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.

If there are any questions, please contact Michael McCoy at (202)
942-1908 or in his absence, to Jennifer Zatkowski at (202) 942-1911.

							Sincerely,

							H. Roger Schwall
							Assistant Director

cc:	Michael McCoy
	Jennifer Zatkowski

Brian McDonald, Esq.
The Stallion Group
Page 1

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

       DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>