SecProbe.io

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Mail Stop 4-7

May 11, 2005

William Sarine
Chief Executive Officer
Telecomm Sales Network, Inc.
c/o Skye Source, LLC
8621 Gleneagles Drive
Raleigh, NC 27613

Re: 	Telecomm Sales Network, Inc.
Amendment No. 1 to Form SB-2
Filed April 25, 2005
File No. 333-123365

Dear Mr. Sarine:

      We have reviewed your amended registration statement and
your
response letter filed April 25, 2005, and we have the following
comments.  Please amend the registration statement 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.

Amendment No. 1 to Form SB-2

Front Cover of Prospectus

1. We note your revisions in response to prior comment 4.  You
disclose on the cover page and in the prospectus summary that the
selling shareholders will sell shares "at privately negotiated
prices" until a market develops.  That is not consistent with the
requirements in paragraph 16 of Schedule A of the Securities Act
and
Item 501(a)(8) of Regulation S-B.  Those provisions require you to
use a fixed price or price range until a market develops.  You may
disclose that "The selling shareholders will sell at a price of
$x.xx
(or a range) per share until our shares are quoted on the OTC
Bulletin Board and thereafter at prevailing market prices or
privately negotiated prices."  Please revise your cover page,
prospectus summary and elsewhere as appropriate.

Prospectus Summary, page 1

2. We note your revisions in response to prior comments 9 and 10.
In
view of those revisions, revise the beginning of your summary to
state clearly , as you do on page 12, that:

* you have not performed any market studies to determine whether
there is a market for your services;
* you will not know whether there is a market for your services
until
you conduct a marketing study;
* you currently lack the resources to pay for the marketing study
you
need;
* you may not be able to raise the capital you need to conduct the
marketing study; and
* you have not yet engaged any organization to conduct the
marketing
study.

Additionally, we note your revised disclosure on page 12 that you
have budgeted $80,000 to conduct the marketing study.  We also
note
that your financial statements indicate that you have more than
$80,000 in cash, net of liabilities.  Please revise to explain
briefly why you are conducting this offering now, before
conducting
the marketing study.

Risk Factors, page 2

We had only $103,138 of current assets ..., page 2

3. We note that you added this risk factor in response to prior
comment 5.  This risk factor is too vague.  Please revise to
include
sufficient, specific information to assess the risk.  For example,
it
is not clear from this risk factor, as currently written, why
having
$103,138 of current assets at December 31, 2004, poses a risk to
investors.  As a general matter, you should express your risk
factors
in more concrete terms with adequate, but not excessive, non-
generic
detail so that readers may clearly identify and assess the
magnitude
of the risk.  Please revise accordingly.

All of the shares of Common Stock owned by our officers, directors
and consultants
may be resold ..., page 7

4. We note your revisions in response to prior comment 7.  This
risk
factor is now too vague and generic and it could apply to any
company.  Please revise to include sufficient, specific
information
to assess the risk.  For example, based on your previous
disclosure,
it appears that you intend to register resales all of the shares
held
by your officers, directors and consultants.  Please revise to
disclose those intentions and provide adequate, but not excessive,
non-generic detail, including the number of those shares currently
outstanding and the number that may be sold pursuant to Rule 144,
so
that readers may clearly identify and assess the magnitude of the
risk.

Description of Business, page 11

5. Many of your revisions in response to prior comment 10 indicate
that you "will" take various actions in conducting your planned
business.  For example, on page 12, you state that your "services
will facilitate the process by which hardware and software
companies
select and establish relationships with international distributors
for their products" and that you "will align geographic
territories
so that distributors are not directly selling into the same
markets."
These and similar statements indicate a degree of certainty and
development in your business that is not consistent with your
statements that you have not yet determined whether there is a
market
for your services and that you have not begun negotiations to
provide
services to any telecommunications company or any distributor.
Please revise to characterize these statements clearly as your
beliefs or plans.

Management

Executive Officers and Directors, page 20

6. We note your revisions in response to prior comment 13.  Please
revise to clarify briefly in clear everyday language, without
jargon,
what types of products and services Skye Source provides.  Also
clarify which company`s clients, management, and plan you are
referencing.  For example, you currently describe Skye Source`s
business as providing "Information Technology consulting services
and
hardware, software & services solutions for our clients."  This
suggests that they are competitors with Telecomm Sales Network.
In
your revisions, avoid using the term "solutions" and similar
business
jargon.  Instead, briefly describe the services in clear everyday
language.

*   *   *   *   *

      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 response
letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Please submit
the
response letter on EDGAR as correspondence.  Detailed response
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 Andrew Mew, Staff Accountant, at (202) 551-
3377
or Robert S. Littlepage, Jr., Accounting Branch Chief, at (202)
551-
3361 if you have questions regarding comments on the financial
statements and related matters.  Please contact Daniel Zimmerman,
Staff Attorney, at (202) 551-3367 or me at (202) 551-3810 with any
other questions.

Sincerely,

Larry Spirgel
Assistant Director

cc:	James F. Verdonik, Esq.
Daniels Daniels & Verdonik, P.A.
(919) 544-5920 (fax)

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