SecProbe.io

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Mail Stop 0511					October 6, 2004

James Charles, President and Treasurer
Christie Fun, Inc.
P. O. Box 110310
Naples, FL  34108-0106

Re:  Christie Fun, Inc.
        Registration Statement on Form 10-SB
        File No.  0-50951
        Filed September 21, 2004

Dear Mr. Charles:

	    This is to advise you that we have reviewed only those
portions of the above registration statement as indicated below and we
have the following comments.

Part I

INVESTMENT COMPANY ACT AND OTHER REGULATIONS, page 6

1. We direct your attention to the letter of January 21, 2000 to Mr.
Ken Worm, Assistant Director of the OTC Compliance Unit at NASD.  This
letter indicates our view that the securities issued by a blank check
company cannot be resold under Rule 144 or Section 4(1) of the Act,
but must be registered under the Securities Act of 1933.   Please
revise the second sentence of the third paragraph to delete any
reference to exemptions from registration of resale of such
securities.  In addition, amend Part II, Item 1, to clarify the
staff`s position on the registration of resale securities as well.

2.     	Please disclose under an appropriate caption the prior blank
check experience involving officers and directors of the Company.
Describe in column format the name of each company.  Include the date
of registration and file number with the Commission, and the current
status of the company`s filings.  Also, state whether any
acquisitions, business combinations, or mergers are pending, have
occurred and the current operating status of each. Any additional
material disclosure should be included.

No further review of your filing will be made at this time.  You are
requested to file an amendment on Form 10SB12G/A to include the
necessary information within fifteen business days, or inform the
staff prior to that time when the amendment will be made.

Other

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.  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 filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff 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.

******

	Please be advised that your registration statement will
automatically become effective 60 days after filing.  Upon
effectiveness, you will become subject to the reporting requirements
of the Securities Exchange Act of 1934, even if we have not cleared
your comments.  In the event that it appears that you will not be able
to respond by the 60th day, you may wish to consider withdrawing your
registration statement and refiling when you have prepared a response
to our comments.  In addition, should the filing become effective in
its present form the Division would be required to consider what
recommendation, if any, it should make to the Commission.

	Any questions on the above matters may be directed to the
undersigned at (202) 942-2999 or Goldie B. Walker at (202) 942-1986.

					Sincerely,

					John D. Reynolds, Assistant Director
					Office of Emerging Growth Companies
					Division of Corporation Finance

James Charles, President and Treasurer
Christie Fun, Inc.
October 6, 2004
Page 3

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