SecProbe.io

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January 19, 2005

Mail Stop 4-9

Via U.S. Mail and Facsimile

Tim Daniels
President, Chief Financial Officer and Director
Dittybase Technologies, Inc.
Suite 102, 31 Bastion Square
Victoria, BC
Canada V8W1J1

	Re:	Dittybase Technologies, Inc.
		Registration Statement on Form 20-F
		Filed December 20, 2005
		File No. 0-51082

Dear Mr. Daniels:

      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
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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F
1. Please note that the Form 20-F goes effective by lapse of time
60
days after the date filed pursuant to Section 12(g)(1) of the
Securities Exchange Act of 1934.  If you cannot address our
comments
within the 60-day time period, you will become subject to periodic
reporting requirements under the Exchange Act.  Alternatively, you
may withdraw the Form 20-F prior to effectiveness and refile a new
Form 20-F including changes responsive to our comments.

Item 1, Identity of Directors, Senior Management and Advisors
2. Supplementally tell us why you have not disclosed the identity
of
a sponsor for listing.
3. Revise to provide the currency exchange rate information at the
latest practicable date, including the average exchange rate for
December, 2004. Refer to Item 3.A.3(a) of Form 20-F.

Item 3. Key Information

Selected Financial Data, page 5
4. Revise the tables to reflect the historical financial data of
the
company for the five most recent financial years, and to provide
comparative data from the prior year for the interim period data.
Refer to Item 3.A. of Form 20-F.

Capitalization and Indebtedness, page 6
5. Please revise your disclosure to include the amount of
indebtedness outstanding.  Refer to Item 3.B. of Form 20-F.

Risk Factors

General
6. Add a risk factor discussing your debt obligations and the
risks
involved should you fail to meet those obligations.  We note the
20%
interest rate on one of your loans.  In addition, you should
discuss
the extent to which you have failed to meet past debt obligations
such as with Hewlett-Packard as discussed on page 11.  It appears
from footnote 5 of your financials that Hewlett-Packard obtained a
judgment against you that you are accounting for to date.
7. Consider adding a risk factor briefly summarizing the material
tax
consequences to US investors who hold or will hold your shares as
described on page 36.  Discuss also the probability of your
becoming
a passive foreign investment company and the risks involved with
such
a designation as described on page 39.
8. Consider adding a risk factor discussing the impact of any
interruptions in internet service, security breaches, or computer
virus attacks may have on your business. We note that your website
ceased to function in 2002.

The Company`s limited operating history...page 6
9. It is unclear how you determined that you have a limited
operating
history that poses a risk to investors given that you began
operations in 1999?  Please advise.  Also, revise this risk factor
to
describe more fully the risks you expect are typical of an early
stage company and the ones that are specific to your business in
particular.  Refer to Item 3.D. of Form 20-F.

The Company`s business has only recently been launched...page 6
10. Revise to disclose a brief history of your operations.  For
example, it should be clear that you launched a website in the
past
that later ceased to function and that your business was more
recently largely dependent on manual sales of your product instead
of
internet sales.  Discuss also the significance to your business of
the website and the services you provide through that website.  In
a
separate risk factor you should discuss your limited customer base
including, the number of customers and musical libraries, and a
discussion of the obstacles you have encountered in attracting a
new
customer base or adding music libraries to date.  Revise to make
this
disclosure more meaningful by explaining what a sufficient
customer
base is, why it is important to your business specifically, and
why
your success is also dependent on the addition of music libraries.

Doubt about the Company`s ability to continue...page 7
11. Expand to state that you have yet to generate revenue (if
true),
you have experienced significant losses since your inception, you
are
operating on a working capital deficiency of Cdn$1,306,058 at
September 30, 2004, and that your accountants have issued an
explanatory paragraph about your ability to continue as a going
concern.  Discuss also any obstacles you have encountered in
raising
capital or securing financing to date.

The Company success will de dependent upon its ability to
adapt...page 7
12. Expand to specify the types of technological advances you
refer
to here.  Also, revise to discuss more specifically how you have
adapted to technological advances, and what efforts you have made
to
that end to date.

The Company has incurred net losses since inception...page 7
13. Quantify the net loss for the most recent period as compared
to
the same period last year.

The market for Internet services is intensely competitive-page 7
14. This risk factor is too general to provide an investor with an
accurate picture of the risks specific to your industry.  Revise
the
heading and the text of this risk factor to briefly identify your
products, your industry, and the level of competition in your
specific industry.  Also, disclose your competitive position
within
that industry, including the basis for your conclusion.  Finally,
discuss more specifically your knowledge regarding the
developments
of your competitors, including the basis for your statements.

The Company`s success will depend primarily upon the
development...page 7
15. How is this risk factor different from the preceding risk
factor?
Also, it is unclear how Dittybase`s success is dependent on the
expansion of Internet products and services in general given that
the
market for Internet services in the most general sense appears to
be
well established. Please advise or delete this risk factor and
specify in the preceding risk factor the risks related to your
product and industry specifically.

To date, the Company`s electronic commerce and Internet
applications...page 7
16. Revise to specify what Internet applications you are referring
to
and define what you mean by "electronic commerce." Discuss more
specifically your marketing position.  For example, when exactly
was
the marketing launched, and what are the expected time frames you
mention?
17. Revise the first sentence to state, if true, that you have
generated no revenues to date, or disclose the revenues generated
for
the most recent interim period.  We note that you refer to sales
made
in your Business history section beginning on page 11, however,
you
have recorded no revenues in your financial statements.

The Company`s success will depend upon the continued services of
its
senior management team...page 8
18. Disclose the names of the key personnel you refer to here.

The possible issuance of additional shares...page 8
19. State also that you may issue more shares to fund your
operations.  We note on page 21 your statement that virtually all
funding for operations has come from common share issuances and
that
as an immediate strategy, you intend to raise capital through
private
or public offerings.

20. Expand to state that your board has the authority without
further
shareholder approval to issue preferred stock with rights superior
to
those currently held by your common stock holders.

Conflicts of Interest...page 9
21. Tell us the basis for your belief that there may be conflicts
of
interest of your directors and/or directors from time to time.

There will continue not to be a market for the Company`s
stock...page
9
22. Disclose whether you are currently applying for listing on the
NASD OTC, and the status of any application.  Please revise to
clarify that your stock is illiquid and that a trading market for
your common stock may never develop.  Revise to discuss the penny
stock risks as a separate risk factor.  In the new risk factor,
state
the basis for your belief that Dittybase stock will be subject to
the
penny stock rules.

Business Overview, page 11
23. Please substantially revise this section so that an investor
may
better understand how you generate revenues and locate customers,
suppliers and sources of financing. In addition, please revise to
distinguish the products you currently offer from those you intend
to
offer in the future.  Similarly, revise to clarify your current
customers, suppliers, material agreements, operations and sources
of
revenue from future plans and prospects.
24. Expand the first paragraph to discuss the developmental status
of
Dittynet.
25. In the penultimate sentence of the first paragraph describe
the
function of your "distribution agents." Are you referring to the
partnerships you have with the music libraries?  Please explain
further in your document so that the disclosure is clear to an
investor who is evaluating your business and industry for the
first
time.
26. In the second paragraph, describe further what you mean when
you
say you aim to "automate" the process of licensing music for
broadcast.  In addition, instead of using the term "solution,"
please
describe your actual services.  Its use implies that a problem is
being solved when in fact none has been presented.

Three Year History

From December 2000 to December 2001, page 11
27. Update the status of your relationship with CBC Records,
Cinetrax
Production Music Library, Music People Library, Inc., and Audio
Network Library of London England.  Did your partnerships with
them
continue after your website was removed from the internet in 2002
and
were they later re-established?  Tell us why you have not filed
any
specific agreements with the above named entities as exhibits.
Please also revise to describe the material terms of each
agreement
and clarify what a "strategic partnership" is.
28. Expand the penultimate sentence of the first paragraph to
explain
further the "technology sector correction" you refer to here.

During the Year Ended December 2002, page 11
29. Clarify whether the functionality of your website ceased as a
result of the failure to meet your lease/debt obligations and the
return of the leased equipment to HP, or for some other reason.
30. Update the developmental status of Decibel Collective.

During the Year Ended December 2003, page 12
31. Please revise here and in the next paragraph to clarify that
the
shares were issued privately.  Please identify the purchasers and
the
business reasons for these private issuances.

During the Nine Month Period Ended September 30, 2004, page 12
32. State the date in which you eventually re-launched your
website.

Operational Overview
33. Revise to clarify what you mean by "publishing acquisition" in
the second bullet point.
34. Please describe any confidentiality or intellectual property
agreements.

Industry Overview-Beginning on Page 13
35. Provide supplemental support for the estimates you quote from
the
National Music Publishers Association, marking the relevant
portions
for our review.
36. We note your statement that the sources of revenue listed have
"relevance" to the company.  Revise to identify which of the
listed
sources are used by Dittybase currently in deriving revenue, and
clarify to readers why the other sources are of "relevance" to
Dittybase.

Operating Results of the Company-Beginning on Page 19
37. Remove the reference to the safe harbor protections under the
Private Securities Litigation Reform Act on page 18. See the
exclusion for penny stock issuers in Section 21E of the Securities
Exchange Act of 1934.
38. Revise to disclose any revenues earned during the stated
periods.
Also, the information provided should be displayed as those
revenues
earned from each segment, for example, those revenues earned from
your "internal customers" versus those earned from your "external
customers." Provide similar information for the expenses incurred
from each segment. See Item 5 of Form 20-F.
39. We note that for each period, you only state the amount and
percentage of change for each significant type of expense,
including
website costs, loss on termination of capital leases, general and
administrative expenses, decreases due to delays in making
payroll,
telephone and internet expense, increase of capital assets, and
expanded trade payables.  Please revise to describe the
significant
factors that have affected the results of operations or which will
affect your future plans.  Refer to Item 5 of Form 20-F and SEC
Release 33-8350.  For example, for each period, describe the
website
costs, what amounts still need to be paid and explain why website
costs are being amortized from prior periods. For instance,
describe
the circumstances and effects of the termination of capital lease,
the delays in making payroll and the cessation of your website.
Further, describe your capital assets and expanded trade payables.
Revise to explain whether the telephone and internet expense are
fixed costs or whether they are business development costs.

Liquidity and Capital Resources-Beginning on Page 20

Capital Requirements
40. Please provide more detailed information about your cash
requirements during the next 12 months, and how you plan to meet
these requirements.  Specifically address whether you intend to
pay
items currently outstanding such as salaries and litigation
payables,
and what amounts you plan to spend on capital assets.  Refer to
Item
5.B.3. of Form 20-F.
41. Discuss liquidity on a long-term (greater than 12 months)
basis.
42. Discuss the status of any efforts in obtain financing, such as
bank loans, to date.
43. Provide the information required by Item 5.B.1.(c) and Item
5.B.2. and 3 of Form 20-F.

Tabular Disclosure of Contractual Obligations-- page 21
44. Provide the information required by Item 5.F.1. of Form 20-F.
At
a minimum, this should include your outstanding debt, lease
obligations and litigation payable.

Research and Development-page 21
45. Provide the information required by Item 5.C. of Form 20-F.
We
note that Mr. Knutsen serves as a vice president of your Research
and
Development division.

Trend Information-page 21
46. Provide the information required by Item 5.D. of Form 20-F.

Directors, Senior Management and Employees

Summary Compensation Table-Page 24
47. Please revise to include all non-cash compensation, including
stock and in-kind benefits.  Refer to Item 6.B.1. of Form 20-F.
We
note that your officers and directors own common stock, as
disclosed
on page 25.
48. Tell us why you have not included the compensation information
for Bruce Urquhart.
49. The table should include the unpaid salaries and advances to
directors mentioned on page 26 of the Related Party Transactions
section.  See Item 6.B.1. of Form 20-F.

Defined Benefit or Actuarial Plan Disclosure-Page 25
50. We note on page 31 your statement that the directors of
Dittybase
may choose, on behalf of the company, to pay a gratuity or pension
on
retirement to