SecProbe.io

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Mail Stop 3561
								November 25, 2005
Sheldon Goldberg
Suite 400 - 601 W. Broadway
Vancouver, B.C.,
Canada V5Z 4C2

Re:	Sockeye Seafood Group, Inc.
Item 4.01 Form 8-K
      Filed 11/17/05
File No.  000-51197

Dear Mr. Goldberg:

      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 more
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.

1. 	We note that you have engaged an audit firm based in
Malaysia.
Please tell us how you concluded that it is appropriate to have an
auditor based in Malaysia in light of the fact that none of your
assets are located in Malaysia, none of your revenues are derived
from Malaysia, and your corporate offices are not located in
Malaysia.   In accordance with Article 2 of Regulation S-X, we
believe that the audit report of a registrant (that is not a
foreign
private issuer) should ordinarily be rendered by an auditor
licensed
in the United States.  Further guidance may be found in Section
5.K
of "International Reporting and Disclosure Issues in the Division
of
Corporation Finance" on the Commission`s website at
http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm
#P4
42_69217Please.  Please advise.

2. 	Additionally, the audit firm Esther Yap & Co. is not
recognized
by the staff of the SEC.  Foreign auditors that wish to practice
before the SEC are expected to demonstrate their knowledge and
experience in applying U.S. GAAP, PCAOB Standards, SEC financial
reporting rules and SEC requirements prior to inclusion of their
audit reports in SEC filings.  The demonstration of an auditor`s
knowledge and experience in advance of filing generally applies to
all financial statements presented in SEC filings, including
financial statements provided pursuant to Rule 3-09 of Regulation
S-
X. Please note that registration with the PCAOB does not supercede
existing means by which a firm demonstrates its knowledge and
experience in applying US GAAP, PCAOB Standards, SEC financial
reporting rules and SEC independence requirements.  You may refer
to
the International Reporting and Disclosure Issues Outline
available
on our website at the following location for additional
information:
http://www.sec.gov/divisions/corpfin/internatl/cfirdissues1104.htm
#P3
13_42976.  Therefore, we do not believe Esther Yap & Co. should
peform any significant audit procedures until Esther Yap & Co. has
demonstrated this knowledge and experience to the Office of the
Chief
Accountant.  In order to begin this process Esther Yap & Co.
should
inquire with the Office of the Chief Accountant (202-551-5300) and
request the information to begin this process.  Upon receipt of
this
request, the Office of the Chief Accountant will provide a letter
outlining the steps and information necessary to complete the
review.
Please advise us of Esther Yap & Co.`s plans to complete this
process.

       As appropriate, please amend your filing and respond to
these
comments within five business days or tell us when you will
respond.
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 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.

	If you have any questions, please call me at (202) 551-3774.

							Sincerely,

							Blaise A. Rhodes
							Staff Accountant

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE

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