SecProbe.io

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December 29, 2004

By facsimile to (403) 272-3620 and U.S. Mail

CSC Services of Nevada, Inc.
502 East John Street
Carson City, NV 89706

RE:	Safer Residence Corporation
	Registration Statement on Form SB-2
	Filed December 2, 2004
File No. 333-120926

To Whom It May Concern:

	We reviewed the filing and have the comments below.

	Where indicated, we think that you should revise the document
in
response to the comments.  If you disagree, we will consider your
explanation why a comment is inapplicable or a revision is
unnecessary.  Be as detailed as necessary in your explanation.  To
understand better your disclosure, we may ask you in some comments
to
provide us supplemental information.  We may raise additional
comments after reviewing this information.

	Our review`s purpose is to assist you in your compliance with
applicable disclosure requirements and to enhance the overall
disclosure in your document.  We look forward to working with you
to
achieve these objectives.  We welcome any questions that you may
have
about comments or any other aspect of our review.  You may call us
at
the telephone numbers listed at the end of this letter.

General

1. Disclosure in the use of proceeds section states that shares of
common stock sold to Safer Residence`s affiliates, directors, and
officers are restricted and are being registered in this offering.
Since those restricted securities may be registered only for
resale
and disclosure elsewhere indicates that no current shareholders
are
selling any of the shares being offered, revise the disclosure,
including the information required by Item 507 of Regulation S-B.

2. Explain the meaning of any abbreviation or acronym when
introduced
in the registration statement.  For example, refer to "RCMP" in
the
first table in the use of proceeds section.

Registration Statement`s Cover Page

3. Since Safer Residence is relying on Rule 415 of Regulation C
under
the Securities Act, add a box to that effect on the cover page.
See
telephone interpretation 36 in section D of our July 1999 "Manual
of
Publicly Available Telephone Interpretations" that is available on
the Commission`s website at http://www.sec.gov.

Prospectus` Outside Front Cover Page

4. Revise the table to show also the minimum offering amount.  See
Item 501(a)(8)(iv) of Regulation S-B.

Table of Contents

5. Move the information after the table of contents so that it
follows the summary and risk factors sections.  See Item 502(b) of
Regulation S-B.

Prospectus Summary

6. Clarify that if Safer Residence fails to raise at least $25,000
of
the $80,000 that Safer Residence is seeking from the offering,
Safer
Residence will have to find other methods to raise additional
funds
and has no additional sources of funds in place.  We note the
disclosure in the plan of operation section.

Risk Factors

7. Include in each risk factor`s discussion information necessary
to
assess the risk, including its magnitude.  For example:

* The first risk factor states that Safer Residence may require
additional financing to establish profitable operations.  Quantify
the anticipated or known amount of additional financing that Safer
Residence may require to establish profitable operations.

* The third risk factor states that Safer Residence has few assets
and does not expect to have revenues until at least three months
after the registration statement becomes effective.  Quantify
Safer
Residence`s assets.

8. Clarify in the third risk factor that Safer Residence is a
development stage company and that Safer Residence only has funds
available to complete this offering`s expenses and has no
anticipated
sources of additional funds in place.

9. Disclosure  in the description of business section indicates
that
factors such as decisions of Safer Residence`s board of directors
not
to pursue a specific course of action or general economic
conditions
may cause Safer Residence`s results or plan of operation to vary.
Address in a discrete risk factor the risks such as those cited
that
may cause Safer Residence`s results or plan of operation to vary
and
the consequences or effects for Safer Residence and its investors.

10. Disclosure in the description of business section indicates
that
there are other companies performing the task of video taping
property.  Address in a discrete risk factor the risks of
competition
for Safer Residence, a development stage company, and the
consequences or effects for Safer Residence and its investors.

11. Disclosure in the dilution section indicates that existing
stockholders will hold 74.2% and new investors will hold 25.8% of
the
issued and outstanding shares of common stock if 100% of the
offering
is sold.  Address in a discrete risk factor the risks of majority
ownership and control by existing stockholders and the
consequences
or effects for Safer Residence and its other investors.  As
applicable, identify the family relationships of Safer Residence`s
directors and officers.

12. Disclosure in the dilution section indicates that the book
value
of the shares of common stock held by existing stockholders will
increase by $0.0186 per share and the book value of the shares of
common stock purchased by new investors will decrease by $0.726
per
share if the offering is fully subscribed.  Address in a discrete
risk factor the risks of dilution and the consequences or effects
for
Safer Residence and its new investors.  Address in another
discrete
risk factor the risks of dilution and the consequences or effects
for
Safer Residence and its investors if Safer Residence obtains
additional financing.

13. Disclosure in the market for common equity and related
stockholder matters section indicates that Safer Residence has no
expectations to pay cash dividends.  Address in a discrete risk
factor the risks of no cash dividend payments and the consequences
or
effects for Safer Residence and its investors.

14. Disclosure in the market for common equity and related
stockholder matters section indicates that Safer Residence
affiliates
hold 2.3 million shares of common stock that will be available for
resale to the public after August 19, 2005.  Address in a discrete
risk factor the risks of market overhang by the 2.3 million shares
of
common stock eligible for sale in the future and the consequences
or
effects for Safer Residence and its investors.

15. Since Ms. Jean L. Blanchard, Ms. Melissa Blanchard, and Mr.
Stephen Lisik, Safer Residence`s directors and officers, are
Canadian
residents, include risk factor disclosure of the difficulty that
may
arise in attempting to effect service or process on them in Canada
or
in enforcing a judgment against Safer Residence`s assets located
outside of the United States.

Plan of Distribution

16. We note the disclosure that Safer Residence may employ the
services of an agent or intermediary to introduce Safer Residence
to
prospective subscribers to the offering.  Describe in the
prospectus
the circumstances under which Safer Residence would expect to
employ
an agent or intermediary to introduce Safer Residence to
prospective
subscribers to the offering.  Tell us whether Safer Residence has
identified already any agents or intermediaries and what
consideration Safer Residence has given to whether such a finder
would be deemed a broker under section 15 of the Securities
Exchange
Act of 1934.

17. Tell us whether Safer Residence intends to advertise the
offering.  Provide us copies of any materials that Safer Residence
intends to use.

18. Tell us whether Safer Residence has any arrangements with any
third party to host or access the preliminary prospectus on the
Internet.  If so, identify the party and the website, describe the
material terms of the agreement, and provide us a copy of any
written
agreement.  Also provide us copies of all information concerning
Safer Residence or the prospectus that has appeared on the third
party`s website.  If Safer Residence enters subsequently into such
an
arrangement, supplement promptly the response.

19. State clearly in the prospectus that changes in the material
terms of the offering after the registration statement`s
effectiveness will terminate the offering and would require a new
offering that may be made by a post-effective amendment to the
registration statement rather than a new registration statement.
Examples of material changes include:

* Extension of the offering period.

* Change in the offering price.

* Change in the application of proceeds.

Disclosure of Commission Position of Indemnification for
Securities
Liabilities

20. We note the disclosure that Safer Residence under its bylaws
is
authorized to indemnify its directors to the fullest extent
authorized under Nevada law "subject to certain specified
limitations."  State what the specified limitations are.

Description of Business

      Competition and Competitive Strategy

21. Discuss briefly the methods of competition in home security
assistance services.  See Item 101(b)(4) of Regulation S-B.

22. Absent additional disclosure, there appears to be no
reasonable
basis for this statement:

"We believe that Safer`s attention to detail, the encompassing
nature
of our business plan, and the assistance we will provide
customers,
especially to those who become victims of crime, gives us a clear
advantage over our competition."

	Revise or advise.

Report of Independent Registered Public Accounting Firm

23. Request the auditors to revise their report to include a
conformed signature as required by Rule 2-02(a) of Regulation S-X
and
Regulation S-B.

24. We note the audit report was signed by Morgan & Company, an
audit
firm registered with the Public Company Accounting Oversight Board
(United States) and based in Vancouver, Canada.  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 be made
ordinarily by an auditor licensed in the United States.  Further
guidance may be found in section 5.J of "International Reporting
and
Disclosure Issues in the Division of Corporation Finance" that is
available on the Commission`s website at
www.sec.gov/divisions/corpfin/internatl/issues 1004.  Since Safer
Residence is incorporated in Nevada, tell us why Safer Residence
selected an auditor licensed outside of the United States to audit
its financial statements.  Tell us where the audit was physically
performed and where the operations and assets of Safer Residence
are
physically located.  Since it is Safer Residence`s responsibility
to
provide financial statements audited by an auditor who meets the
requirements of Rule 2-01(a) of Regulation S-X, tell us how Safer
Residence determined that its auditor meets the requirements of
Rule
2-01(a) of Regulation S-X.  Also tell us what consideration Safer
Residence gave to Nevada state laws governing audits of Nevada
companies performed by foreign auditors.

Exhibits

25. Include an exhibit index immediately before the exhibits.  See
Item 601(a)(2) of Regulation S-B.

26. We assume that investors will use a form of subscription
agreement to subscribe for shares in the offering.  File the
subscription agreement as an exhibit to the registration
statement.

Exhibits 5 and 23.1

27. We note that Safer Residence will file by amendment the
exhibits.
Allow us sufficient time to review the exhibits before requesting
acceleration of the registration statement`s effectiveness.

Closing

	File an amendment to the SB-2 in response to the comments.
To
expedite our review, you may wish to provide us three marked
courtesy
copies of the amendment.  Include with the filing any supplemental
information requested and a cover letter tagged as correspondence
that keys the responses to the comments.  If you think that
compliance with any of the comments is
inappropriate, provide the basis in the letter.  We may have
additional comments after review of the amendment, the responses
to
the comments, and any supplemental information.

	We urge all persons responsible for the accuracy and adequacy
of
the disclosure in the registration statement reviewed by us to
ensure
that they have provided all information investors require for an
informed decision.  Since Safer Residence and its management are
in
possession of all facts relating to the disclosure in the
registration statement, they are responsible for the adequacy and
accuracy of the disclosures that they have made.

	If Safer Residence requests acceleration of the registration
statement`s effectiveness, Safer Residence should furnish a letter
at
the time of the request, acknowledging that:

* Should the Commission or the staff acting by delegated authority
declare the registration statement effective, it does not
foreclose
the Commission from taking any action on the filing.

* The action of the Commission or the staff acting by delegated
authority in declaring the registration statement effective does
not
relieve Safer Residence from its full responsibility for the
adequacy
and accuracy of the registration statement`s disclosures.

* Safer Residence may not assert the action of the Commission or
the
staff acting by delegated authority in declaring the registration
statement effective as a defense in any proceedings initiated by
the
Commission or any person under the United States` federal
securities
laws.

	The Commission`s Division of Enforcement has access to all
information that you provide us in our review of the registration
statement or in response to our comments on the registration
statement.

	We will consider a written request for acceleration of the
registration statement`s effectiveness under Rule 461 of
Regulation C
under the Securities Act as confirmation that those requesting
acceleration are aware of their responsibilities under the
Securities
Act and the Exchange Act as they relate to the proposed public
offering of the securities specified in the registration
statement.
We will act on the request and by delegated authority grant
acceleration of the registration statement`s effectiveness.

	You may direct questions on accounting comments to Bret A.
Johnson, Staff Accountant, at (202) 824-5478 or Anne M. McConnell,
Senior Staff Accountant, at (202) 942-1795.  You

may direct questions on other comments and disclosure issues to
Edward M. Kelly, Senior Counsel, at (202) 942-1978 or me at (202)
942-2864.

Very truly yours,

Jennifer R. Hardy

Legal Branch Chief

cc:	W. Scott Lawler, Esq.
	1530-9 Avenue SE
	Calgary, Alberta, Canada T2G 0T7
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CSC Services of Nevada, Inc.
December 29, 2004
Page 8

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

         DIVISION OF
CORPORATION FINANCE

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