SecProbe.io

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Mail Stop 4-7

September 23, 2004

Heather Remillard
President
Sound Revolution Inc.
Suite 507 - 3955 Graveley Street
Burnaby, British Columbia
Canada, V6C 3T4

RE: 	Sound Revolution Inc.
Form SB-2
Filed August 20, 2004
File No. 333-118398

Dear Ms. Remillard:

We have reviewed your registration statement and have the following
comments.  Please amend the registration statement 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 filings.  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 SB-2

General

1. We note that this exclusively secondary offering is the initial
offering of your common shares.  We also note that while you are not
receiving any proceeds from the offering, the company is paying the
costs associated with this registration statement even though you
apparently are under no obligation to do so.  We further note that
your common shares do not trade on any market or quotation system, yet
you intend to pursue a listing on the OTC Bulletin Board after this
registration statement is declared effective.  Based upon these and
other factors, it appears that the selling shareholders may be
statutory underwriters within the meaning of the Securities Act.
Please tell us whether the selling shareholders have purchased from
the company with a view to, or are engaging in the direct or indirect
participation in, a distribution of your shares.  If any of the
selling shareholders are statutory underwriters, then they must be
named as such and the prospectus must be revised accordingly.

Your response analyzing whether the selling shareholders may be
statutory underwriters should include, but not be limited to, the
following factors:

* how long the selling shareholders have held the shares;
* the circumstances under which they received the shares;
* their relationship to the issuer;
* the amount of shares involved;
* whether the sellers are in the business of underwriting securities.

We may have additional comments based upon your response.

2. Please supplementally advise us whether any of the selling
shareholders are broker-dealers or affiliated with broker-dealers.
For all selling shareholders that are broker-dealers, disclose that
they are "underwriters" within the meaning of the Securities Act.  You
should revise the Plan of Distribution to state the names of the
selling shareholders who are broker-dealers, and to state that they
are also underwriters with respect to the shares that they are
offering for resale.

3. For selling shareholders who are affiliates of broker-dealers,
disclose, if true, that:

* The seller purchased in the ordinary course of business, and
* At the time of the purchase of the securities to be resold, the
seller had no agreements or understandings, directly or indirectly,
with any person to distribute the securities.

If these statements are not true for any selling shareholder, then the
prospectus must state that the selling shareholder is an underwriter.

4. We note that you are a development stage company with little if no
business operations, a capital deficit, and a negative financial
condition.  We also note that your officer, director and principal
shareholder Penny Green previously was an officer, director, and
principal shareholder of another public company - Mediatelevision.tv.
Similar to Sound Revolution`s proposed offering, Mediatelevision
became a public company by means of an exclusively secondary initial
public offering in 2002 despite having little if no business
operations, a capital deficit, and a negative financial condition.  In
the two years since, it does not appear that Mediatelevision`s
business, investment, or financial condition changed.  Then, in April
2004, Mediatelevision announced a reverse merger in which Ms. Green
sold her shares in a change of control transaction to a company with
business operations.  Based upon filed Forms 8-K, it appears that the
sale closed on August 1, 2004.  In light of these facts, please
confirm and explain to us whether Sound Revolution actually intends to
pursue its business model or whether it actually is a blank check
company for which Ms. Green reasonably intends to seek a buyer of a
company with a registered class of shares.  We may have additional
comments based upon your response.

5. Please provide us with copies of any artwork you intend to use as
soon as possible for our review and comment.  Please keep in mind that
we may have comments on these materials and you should consider
waiting for further comments before printing and circulating any
artwork.

6. When referring to dollar amounts, uniformly refer to either US or
Canadian dollars.  Revise throughout the filing.  Also, disclose in
the heading of your financial statements that your financial
statements are in US dollars.

Front Cover of Prospectus

7. Please delete the second and third sentences of the first
paragraph.  Those sentences are neither required by Item 501 of
Regulation S-B, nor appear key to an investment decision.

8. In the third full paragraph, please add a sentence briefly
highlighting that purchasers in this offering may be receiving an
illiquid security.

9. If you intend to circulate preliminary prospectuses, please revise
to include the legend required by Item 501(a)(10) of Regulation S-B.

Inside Front Cover

10. Please provide the dealer delivery obligation disclosure required
by Item 502(b).

Prospectus Summary, page 1

11. Please revise the Sound Revolution Inc. discussion to emphasize
more clearly that you have no operations, have not generated any
revenues, and do not expect to commence operations and generate
revenues until the middle of 2005.

12. Please revise to include a brief statement indicating what
percentage of your common stock is being offered in this prospectus.
Also clarify that both before and after the offering, your current
directors and officers will control the company.  Name those directors
and officers and state the percentage they will hold in your common
stock.  Also state that you are a subsidiary of Bacchus Entertainment
Ltd., a company which is 100% owned by your chairman, Penny Green.
Clarify what percentage of your shares are owned by Bacchus.

13. In the discussion of financial condition, please revise to include
a brief statement disclosing the amount of financing you expect to
require to continue in operations for the next year.

14. Please generally revise your registration statement to eliminate
technical and business jargon from the prospectus summary and to
reduce the amount of jargon throughout the rest of the prospectus.
Examples of terms that you should consider replacing with clear
concrete everyday language are:

* "fan management software product"
* "software that will allow artists and record labels to maximize
sales potentials"
* "developing digital music distribution services"
* "We intent to distribute our digital music online through seamless
digital integration."
* "music distribution end to end solutions"
* "Major labels are top-heavy and have high overheads"
* "break-even points"
* "digital content" and other variations on "content"

Risk Factors, page 2

15. Some of your risk factors are too long, too vague, too generic or
bundle multiple risks under one risk factor.  Meaningful risk factor
disclosure should clearly present adequate but not excessive detail
about distinct risks to your company or your offering.  For example,
please revise the following risk factors:

* "Because of our lack of operating history, we face a high risk of
business failure," page 2.  This risk factor  is too vague in that you
do not present sufficient, but not excessive, information for
investors to assess the magnitude of the risk.  Please revise
accordingly. As currently drafted this risk factor is also generic in
that it could apply to any company.  Please revise to clearly explain
how each risk applies to your industry, company, or offering.
Additionally, please revise the bodies of this and your other risk
factors so that the bodies of the risk factors explain how the risk
described in the caption may occur.
* "Our operating results may prove unpredictable ...," page 3.  This
risk factor bundles together multiple distinct risks.  In order to
give the proper prominence to each risk you present, please assign
each risk its own descriptive subheading.
* "We are a development stage online music distributor with no
experience ...," page 4.  This risk factor bundles several distinct
risks.  In doing so, you do not provide sufficient concrete detail for
investors to understand the magnitude of these risks.  Please revise
accordingly.  Once you revise to unbundle this and other risk factors,
as currently drafted, you should consider replacing repetitive risk
disclosure with a single risk factor.  For example, this and the
preceding two risk factors discuss the risk that you may not be able
to continue in operations without raising significant amounts of new
equity financing.

Again, the above are only examples.  Please revise throughout.

16. Please avoid the generic conclusion that a risk could have a
materially adverse effect on you, an adverse effect may result from
the risk, etc.  This does not represent meaningful disclosure, whether
in your risk factor captions or discussions.  Revise to specifically
disclose the actual risk and how it could affect your offering,
operating results, business strategy, profits, share price, etc.

17. Please revise to move the first risk factor following the "Risks
Related to Our Business" on page 4 so that it is the first risk factor
presented.  Also revise that risk factor to clarify that you have no
customers, no current products and no revenues.

Reliance on certain alliances, page 7

18. Please revise this caption to reflect the risk discussed in the
body of the risk factor.  Similarly revise your other risk factor
captions as appropriate, including "Change in technology environment
and access" on page 9.

A limited number of stockholders control us ..., page 12

19. Please revise this risk factor to clearly state and explain a risk
to investors.  State what adverse effect may occur and what may cause
it.  Similarly revise your other risk factors as appropriate,
including "We indemnify our directors ..." and "We have never paid
dividends" on page 12.

Determination of Offering Price, page 13

20. Please revise to disclose the factors you considered in
determining the offering price.  Since this is the initial offering of
your shares, it is unclear how you or the selling shareholders -
individually or in groups of shareholders and/or with the company -
arrived at the initial offering price of $0.20 per share.  Similarly,
it is unclear what privately negotiated factors might lead the selling
shareholders to sell shares at a price different than $0.20 per share.

21. In addition, please briefly describe in the summary how the
offering price was determined.

Plan of Distribution, page 15

22. Please revise your disclosure here to clarify that, in order to be
quoted on the OTC Bulletin Board, a market maker must file an
application on your behalf in order to make a market for your common
stock.  Clarify how long this takes and whether you have engaged a
market maker to apply for quotation on the OTC Bulletin Board on your
behalf.  Explain what effect quotation on the OTC Bulletin Board will
have on your liquidity.

Similarly, include a very brief statement about these items in the
prospectus summary.  Also, please revise the risk factor "The
securities offered may qualify as penny stocks..." on page 10, to
incorporate these details.

23. Please identify any selling shareholders that will engage in any
electronic offer, sale or distribution of the shares and describe
their procedures to us supplementally.

Further, tell us whether you or the selling shareholders have any
arrangements with a third party to host or access your prospectus on
the internet.  If so, identify the party and the website, describe the
material terms of your agreement, and provide us with a copy of any
written agreement.  Provide us also with copies of all information
concerning your company or prospectus that have appeared on their
website.

Directors and Officers, page 16

24. Please remove your discussion of Digital Color Print, Inc.`s,
current stock price.

Audit Committee, page 18

25. Please revise to name the member of your audit committee.

Description of Securities, page 19

26. The statement "All outstanding shares of Common Stock are validly
authorized and issued, fully paid and non-assessable" is a legal
conclusion you are not qualified to make.  Either attribute it to
counsel or delete it.

27. Please remove your statement that the description of the common
stock does not purport to be complete.  Your Description of Securities
should be materially complete.  See Item 202 of Regulation S-B.
Please revise accordingly.

28. Please revise to describe your preferred stock.  You should state
how many shares are outstanding and in what series, and what material
terms they have.  See Item 202 of Regulation S-B.  In this regard, we
note your disclosure on page 12 in the risk factor "Some provisions of
our articles ...."

Description of Business, page 21

29. Please revise to begin your Business discussion by stating, if
true, that you have only recently begun your current operations and
that you have limited history of revenues and significant operational
losses to date as well as accumulated shareholder deficit.  Provide
quantitative figures for these items and state the dates that you
commenced each material category of your current operations.

30. Please generally revise your Business discussion, from page 21
through 26, to clarify what specific products you intend to distribute
in what specific markets and specifically how you plan to generate
revenues.  Also please generally revise to clearly and precisely state
the stage of development for each of your material products and
services.  Similarly clarify the stage of any material negotiations
and clarify whether you have binding written agreements.  Your current
disclosure is too vague.  For example, please replace the following
statements with concrete everyday language that clearly explains what
you sell, who supplies it to you and to whom you sell it:

* You indicate on page 21 that you have "been developing products and
services that will assist artists in generating new revenue streams
available in the digital economy."  Identify these products and
services and explain how they work.  Identify what type of artists you
are referring to.  Since you have not generated significant revenues,
it is unclear what your basis is to suggest these products and
services will "generat[e] new revenue streams available in the digital
economy."  Please support or remove that and similar statements.
* Also on page 21, you indicate that you "have been developing a
business model for a website that will combine music and charitable
causes for the sale of digital music."  Please revise to provide more
concrete details of this business model and clearly state what
specific steps you have taken to implement it and what steps remain.
Also clearly state