SecProbe.io

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Mail Stop 0308

      May 26, 2005

Scott Sutherland
President
Vika Corp.
Suite 202, 2310 W 2nd Ave.
Vancouver, BC V6K 1J1

Re:  	Vika Corp.
      Registration Statement on Form SB-2
      Filed April 28, 2005
      File No. 333-124421

Dear Mr. Sutherland:

      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
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 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. Your disclosure indicates that you are a development stage
company
established on December 3, 2003, with limited operations, no
revenues, and no significant assets.  You also indicate you have
not
commenced your planned principal operations.  It therefore appears
that your proposed business may be commensurate in scope with the
uncertainty ordinarily associated with a blank check company.
Accordingly, please revise your disclosure throughout your
registration statement to comply with Rule 419 of Regulation C or
provide us with an explanation of why Rule 419 does not apply.

Registration Statement Facing Page
2. In footnote 1 to the fee table, you indicate that the offering
price was determined by the price of shares sold in a Regulation S
offering, yet elsewhere in the registration statement you indicate
that you relied on Regulation D for all previous issuances of
securities.  Please advise or revise to reflect the appropriate
exemption from registration.
3. Please revise footnote 1 to the fee table to indicate that
selling
shareholders "will" sell their shares at the price of $0.20 per
share
until the common stock is quoted on the OTC Bulletin Board.
Provide
similar disclosure on the cover page.
4. Above the delaying amendment, we note the paragraph beginning
with
"The information in this prospectus is not complete . . .".   This
disclosure should appear on the prospectus cover page, rather than
on
the registration statement facing page.  Please revise
accordingly.

Prospectus Cover Page
5. Please delete the last sentence from the first paragraph.
Please
be aware that an issuer does not apply to "list" its common stock
on
the OTC Bulletin Board.  Rather, 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.  Also revise
throughout
the remainder of the prospectus accordingly.

Description of the Business, page 6
6. We note your goal is to become a provider of private and secure
carrier class data and voice network for small and medium size
businesses.  You also state that your target markets are second
and
third tier markets that are either underserved by incumbent
telephone
and cable companies or have no broadband access at all.  These and
similar statements are inappropriate in a summary, given your
limited
operating history and essentially no business operations.  You
should
indicate in the summary that you have received no revenues from
operations, you have only limited operations, you are a
development
stage company and you have received a going concern opinion from
your
auditors.  Please revise accordingly.

7. After "Securities Issued and to be Issued," please add a
separate
paragraph that discloses that your sole executive officer and
director holds 54.2% of your shares, and as a result will exercise
control over your direction.
8. After "Alternative Plan of Distribution," briefly explain how
the
absence of a public market for the common shares impacts share
liquidity.

Risk Factors, page 7
9. Please revise this section to more accurately describe your,
services and management.  References to "our equipment or
facility,
or those of our partners or customers" are inappropriate given
your
status. Similarly, delete the plural nature of the reference to
control by "directors, officers and principal shareholders" and
clearly state that Mr. Sutherland will have control.
10. Please delete in your risk factor section language in your
risk
factors that mitigates the risk.  See, for example, the first
clause
of the fourth sentence in risk factor 4 ("We may lose
customers...");
the fifth sentence in risk factor 4; the first clause in the first
sentence in risk factor 5 ("We depend on Robert Lepage..."); and
the
first clause of the second sentence in risk factor 10 ("There is
no
public market...").
11. In the risk factor "We depend on Robert Lepage. . .", revise
to
explain who Mr. Lepage is and indicate that he provides services
to
you as a consultant.
12. Please revise the captions to your last two risk factors
because
they do not describe the risks to investors.  For example, the
caption to risk factor 12 indicates broker-dealers may be
discouraged
from making trades in penny stocks, but does not refer to the
illiquidity of this stock and how that will affect an investor.
Please review your risk factor captions generally to make sure
they
clearly and concisely describe the risks to investors, rather than
merely stating facts that give rise to the risks.
Determination of Offering Price, page 11
13. You state that the offering price of $0.20 per share was
"arbitrarily chosen."  It is therefore important that the
disclosure
be clear and concise about how you did select an offering price
per
share.  Accordingly, please revise to disclose all factors
considered, including the Regulation S offering referenced in
footnote 1 to the facing page of the registration statement.  For
each factor you cite, briefly explain how these factors affected
your
determination of the offering price.

Selling Shareholders, page 11
14. Please provide a total for each column listed.
15. You indicate that Scott Sutherland owns 700,000 shares prior
to
the offering.  However, on page 17 you show ownership of
15,000,000
shares prior to the offering.  Please revise as necessary.  Update
this information so it as of the most recent practicable date.
16. Please indicate the manner in which the selling shareholders
acquired their shares.
17. Revise the final paragraph in this section that indicates that
none of the selling shareholders have had a relationship with you
other than as a shareholder.  We note that Scott Sutherland, your
sole director and officer, is a selling shareholder.  Please
revise
accordingly.
18. Disclose whether any selling stockholder is a registered
broker-
dealer or an affiliate of a broker-dealer.  If any selling
stockholder is a broker-dealer, disclose that it is an
"underwriter"
within the meaning of the Securities Act of 1933.  You should also
revise the plan of distribution section accordingly.
19. If the selling stockholder is an affiliate of a broker-dealer,
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, then the prospectus must state
that
the selling stockholder is an underwriter.

Plan of Distribution, page 13
20. Please alert investors at the beginning of this section that
there is currently no market for any of your shares, and that you
cannot give any assurance that the shares offered will have a
market
value, or that they can be resold at the offered price if and when
an
active secondary market might develop, or that a public market for
your securities may be sustained even if developed.
21. In this regard, please provide comprehensive disclosure as to
how
and when you expect to have your shares listed or traded.  For
example, if you anticipate being quoted on the OTC Bulletin Board,
then disclose that 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.
22. We note your reference to short sales.  Please advise whether
any
selling stockholders have taken or plan to take any short
positions
prior to effectiveness of this registration statement.  Short
positions prior to effectiveness are inappropriate under Section 5
of
the Securities Act.
23. Please provide the information required by Item 401 of
Regulation
S-B with respect to Robert Lepage.  We note that you have
identified
him as a significant employee, yet elsewhere you have identified
him
as a consultant.  Please clarify.

Significant Employees, page 15
24. Please tell us if the two employees listed here are the same
two
employees you refer to in your disclosures on page 21 under number
of
employees.  If so, please revise your disclosures to delete the
reference to collective bargaining agreement since management is
never represented by such agreement.  If you in fact have four
employees instead of two, please revise your disclosures to
clarify
the actual number of employees.

Legal Matters, page 19
25. Please file your legality opinion as soon as practicable.  See
Item 601(b)(5) of Regulation S-B.

Principal Products and Services, page 19
26. We note your plans to offer services in the telecommunications
industry.  Please explain to us and clarify in your disclosures if
there are any regulatory licenses required from agencies in Canada
in
order for you to offer the products and services you anticipate
selling.  If so, please disclose how you comply with these
requirements.  If there are none, please disclose that there are
no
such requirements.
27. Expand this section to provide detailed information concerning
your operations. This would include the status of any
installations,
servicing work, obtaining equipment, status of marketing
arrangements, etc.  You should provide information regarding all
activities to clearly describe your operating status.  If no
progress
has been made, so state.  You should clarify how you will create a
network that you will monitor with only two employees.  This
description may also need to be addressed in the risk factors
section
28. Describe in further detail where you intend to install and
maintain a wireless point of presence.  Have you determined that
there are sufficient telecommunications towers or buildings that
meet
the "technical criteria for such deployments" in the area you have
selected?  Briefly explain what these criteria are and explain who
will effect any changes that may be required to meet these
criteria
and who will bear the cost.  Also, please explain if you will need
to
obtain licenses or easements or comply with any governmental
regulations.
29. Please explain approximately when you will be in a position,
financial and otherwise, to actively commence your business.  What
are the prerequisites for doing so?

Industry Background, page 20
30. Refer to the last sentence of this section.  Please revise
this
section to more clearly indicate what statements are opinions of
Robert Lepage and explain the basis for these opinions.  Please
provide us with marked copies of the information, studies, data,
etc.
upon which his opinions are based.

Marketing, page 20
31. Indicate, if true, that you will also supply broadband
wireless
capability to individual residences as well as small to medium
size
companies.
32. State the basis for management`s belief that the growth
potential
for this market is         large and provide us with supporting
data.
Otherwise, delete this statement.
33. Please delete the list of marketing tools which you do not
have
the ability to capitalize on at the present time.

Competition, page 22
34. Briefly explain the new Wimax technology and why it is a "true
differentiator" from your competitors.

Technology, page 22
35. Please describe your arrangements for obtaining needed
equipment.

Number of Employees, page 22
36. Please quantify the part-time work of your two employees.

Periodic Reports with the SEC, page 23
37. Revise the statement that indicates that you will become a
voluntary filer.  Upon effectiveness of your registration
statement,
you will be required to file reports with the SEC.

Plan of Operation, page 23
38. We note that you present deferred revenue on your balance
sheet.
Please clarify in your disclosures when you anticipate commencing
operations.
39. Your disclosures in the first paragraph on page 23 regarding
your
cash needs appear to suggest that your primary source of cash
receipts since inception has been loans from your principal
shareholder.  However, your disclosures indicate that through
December 31, 2004 you had received $4,100 in loans from your
principal shareholder, while expenses since inception totaled
approximately $51,000 during the same period.  Please revise your
disclosure to clarify that your primary source of funds to date
has
been through equity financing and provide the amount received.
40. Your disclosures detail approximately $313,000 for the
principal
the types of cost and expenses you expect to incur during the next
12
months.  Please reconcile for us and revise your disclosures to
explain the difference between the amount of funds you expect to
raise of $600,000 disclosed on page 23 and the total amount you
expect to spend.   Please also reconcile the disclosure on page 7
that states that you project that you need to raise $650,000 in
order
to execute your business plans over the next 12 months to the
$600,000 you disclose here.
41. You indicated that as of December 31, 2004, you only had funds
to
continue in business for one month.  Please update your disclosure
to
explain the status of your business and financing since that time.
Also, specifically explain at this time how you will generate
sales
in the next six to 12 months to support your planned ongoing
operations.  Please quantify the cash flow you will need to
support
your operations over the next 12 to 18 months.  See Item 303(a) of
Regulation S-B.

Executive Compensation, page 27
42. Please quantify the financial resources you will need in order
to
start paying Mr. Sutherland a salary.

Financial Statements
43. Please revise to update your financial statements to comply
with
the requirements of Item 310(g) of Regulation S-B.

Report of Independent Registered Public Accounting Firm, page F-2
44. Please include a signed audit report with your next amendment.
Refer to Rule 2-02(a)(2) of Regulation S-X.

Balance Sheets, page F-3
45. Please label the final totals on each side of your balance
sheet.

Statements of Operations, page F-4
46. You disclose in Executive Compensation on page 27 that total
salary paid to date to your President was $18,000, but you
disclose
in the table of annual compensation that he did not receive
compensation for services rendered.  Please revise your
disclosures
in Executive Compensation to clarify this discrepancy.  Further,
you
also disclose on page 23 in the last paragraph that another
employee
rents office space on your behalf.  We believe that your financial
statements should reflect all of the costs of doing business.  If
the
cost of office space is not properly reflected in the financial
statements, please revise your financial statements to reflect the
fair value