SecProbe.io

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March 22, 2005

MAIL STOP 0511

via U.S. mail and facsimile

Elena Krioukova, President
Scala Minerals, Inc.
318 Homer Street, Suite 400
Vancouver, British Columbia
Canada V6B 2V2

Re:      Scala Minerals, Inc.
Form SB-2, amendment 1 filed February 17, 2005
      File No.:  333-121613

Dear Ms. Krioukova:

	We have the following comments on your filing. 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.

General

1. All exhibits are subject to staff review and should be filed as
soon as practicable to allow sufficient time for such review.  If
there are unfiled exhibits which are not filed with the next
amendment, please supplementally provide us with forms of such
exhibits to allow us to comment in a timely manner.
2. We repeat our prior comment #2 regarding our belief that the
registrant is a "blank check" company.  We believe that your
minimal
activities do not support your argument that you have a specific
business plan.  Additionally, with a view towards disclosure,
supplementally provide us with a listing of the following
information: (i) every public entity with which any principal, or
any
affiliate of either a principal or the company has been or is
associated with, including but limited to such principal`s or
affiliate`s involvement as a principal, accountant, consultant,
shareholder (if the company was a development stage company when
it
went public), or promoter; (ii) specify for each such entity the
nature and extent of the principal`s or affiliate`s involvement;
(iii) indicate for each such entity whether or not a principal or
an
affiliate of either a principal or the company was in any way
involved in an offering of securities by such entity and if so
describe in reasonable detail the extent and nature of such
involvement; (iv) for each such entity whether or not such entity
is
or was subject to Rule 419  or otherwise qualifies or qualified as
a
"blank check" company; (v) for each such entity whether or not
such
entity was involved in any merger transaction, including but not
limited to a "reverse merger" transaction, and if so, provide
reasonable detail concerning each such transaction as well as any
principal`s or affiliate`s role in such transaction(s); and (vi)
whether any principal or any affiliate of either a principal or
the
company has ever acted as a broker or dealer in any transaction,
and
if so describe such activities.  We may have further comment.

Directors, Executive Officers, Promoters and Control Persons, page
15

3. Disclose whether Ms. Krioukova has professional training or
credentials in accounting, and if so, please specify such training
and credentials.

Description of Business, page 19

Shore Claims Option Agreement, page 20

4. Please revise this section to clarify whether December 1, 2005
or
July 1, 2007 is the date when there must be $150,000 in
exploration
and development work on the claims.
5. We have reviewed your response to our prior comment 15.  Please
clarify further the meaning of the underlined part of the
following
excerpt from paragraph 5.2 of the Option Agreement:  "Any part of
the
Claims that Scala returns to Sostad in accordance with paragraph
5.1
shall have a minimum of one year of assessment work credited
against
it at the time of return."

Geological Assessment Report:  Shore Claims, page 22

6. You have stated that you have enclosed a copy of Dr. Molak`s
report on the Shore claims.  However, we are unable to locate the
copy of the report.  Please provide us with a copy when you file
your
next amendment to your registration statement.
7. In your description of your two phase exploration program to
further evaluate the Shore claims, please clarify whether the
specific steps you describe were included in Dr. Molak`s report.

Exhibits

8. We note that your supplemental response to our prior comment
#16
has conflicting statements regarding whether or not you have filed
Dr. Molak`s written consent to be named in the registration
statement
in connection with the description of his geological summary
report
of the Shore claims. It is not on EDGAR.  Before the registration
statement goes effective it is necessary to file it as an exhibit
on
EDGAR.
9. Revise the third paragraph of the legality opinion to indicate
that it opines upon Nevada law including the statutory provisions,
all applicable provisions of the Nevada Constitution and reported
judicial decisions interpreting those laws.

Engineering Comment

General

10. The initial engineering comment is re-issued regarding the
small-
scale map showing the location and access to the property.  The
drawing filed as a separate exhibit should conform to the
following
guidelines:

* A legend or explanation showing, by means of pattern or symbol,
every pattern or symbol used on the map or drawing.
* A graphical bar scale should be included.  Additional
representations of scale such as "one inch equals one mile" may be
utilized provided the original scale of the map has not been
altered.
* A north arrow on the maps.
* An index map showing where the property is situated in
relationship
to the state or province, etc., in which it was located.
* A title of the map or drawing and the date on which it was
drawn.
* In the even interpretive data is submitted in conjunction with
any
map, the identity of the geologist or engineer that prepared such
data.
* Any drawing should be simple enough or of sufficiently large
scale
to clearly show all features on the drawing.
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.

      You may contact George Schuler at 202-942-5527 with
questions
regarding the engineering comments.  Please contact Susann Reilly
at
(202) 942-1946 with other questions.

Sincerely,

John Reynolds
Assistant Director
Office of Emerging Growth Companies

cc:  	Elena Krioukova, President
      Facsimile 604-602-7593

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Elena Krioukova
Scala Minerals, Inc.
March 22, 2005
Page 4

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