SecProbe.io

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Mail Stop 3561
      December 6, 2005

Michael Enemaerke
Cross Atlantic Commodities, Inc.
1282 Camellia Circle
Weston, FL 33326

      Re:	Cross Atlantic Commodities, Inc.
      Amendment One to Registration Statement on Form SB-2
      Filed November 16, 2005
		File No. 333-1311294

Dear Mr. Enemaerke:

      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.

Risk Factors, page 7
1. We reissue comment 8 in our letter dated October 7, 2005.  We
note
that you state in your response that you had added a risk factor
addressing the risk concerning your contract with Victoria
Coffees.
It does not appear that you have provided such a risk factor.
Please
revise your Risk Factors to include a risk factor that addresses
the
potential termination of your commodities contract with Victoria
Coffees.

Management`s Discussion and Analysis and Plan of Operations, page
23
2. We note your response to comment 28 in our letter dated October
7,
2005.  Our comment requested that you expand your disclosure to
provide greater details on how your business activities will
generate
revenues, such that the reader could understand your business and
evaluate the likelihood you will make a profit.  Please augment
your
disclosure to provide more information to allow a reader to fully
evaluate your likely performance and profitability.  Please revise
or
advise.
3. We note your response to comment 29 in our letter dated October
7,
2005.  Our comment requested that you include a discussion of
known
trends, or uncertainties that are reasonably likely to have a
material effect on the company`s net sales or revenues, income
from
continuing operations, profitability, liquidity or capital
resources,
or that would otherwise cause reported financial information not
necessarily to be indicative of future operating results or
financial
condition.  Your revisions appear more in the form of additional
risk
factors.  For example, is it a know trend that there could be an
embargo placed on Uganda?  Please revise or advise.

Results of Operations, page 26
4. We note your response to comment 15 in our letter dated October
7,
2005.  You have not revised your discussion of results of
operations
and financial statement footnotes to disclose the difference
between
the nature of the business and operations from October 2004
through
June 30, 2005 and your plan for operations.  You also have not
revised your results of operations to provide a more clear
discussion
which is not merely a recitation of changes evident from your
financial statements.  Your response did not indicate why you
think
these revisions are not necessary.   Please revise or advise.

Plan of Distribution, page 35
5. We note your response to comment 34 in our letter dated October
7,
2005.  Please revise your disclosure to make clear that you can
not
apply to be listed on the OTC Bulletin Board.   In this regard,
ensure that your disclosure clearly discloses that to be quoted on
the OTC Bulletin Board a market maker must file an application on
your behalf.

Financial Statement, page 40
6. Your financial statements were required to be updated prior to
the
filing of this amendment.  In the future please file amendments
with
properly updated financial statements and related disclosures.
Refer
to Item 310 of Regulation S-B.

Item 26. Recent Sales of Unregistered Securities, page 57
7. Please more fully describe the legal and factual basis of the
exemptions from registration you relied upon in these
transactions.
For example, you state that one of your transactions was exempt
under
an exemption under 4(2).  Do you mean to simply state that it was
non-public offering under 4(2) or did you rely upon a specific
exemption under Regulation D?  If so please provide the factual
basis
that would allow you to rely on this exemption.  Please note this
is
an example.  Review your entire Recent Sale of Unregistered
Securities section and revise as necessary.  See Item 701(d) of
Regulation S-B.

Exhibits

Exhibit 23.1 Consent of Independent Registered Accounting Firm
8. Please ensure you obtain and file an updated signed consent of
your independent auditors.  Ensure that the consent reflects an
appropriate electronic signature (/s/).

Non-Binding Letter of Intent
9. Please either file as an exhibit your Non-Binding Letter of
Intent
with Martell, LLC or explain to us why it`s not material.

***

      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 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 Adam Phippen, Accountant, at (202) 551-3336
or
George Ohsiek, Accounting Branch Chief, at (202) 551-3843 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact Scott Anderegg, Staff Attorney, at (202)
551-3342, David Mittelman, Legal Branch Chief, at (202) 551-3214
or
me at (202) 551-3720 with any other questions.

      					Sincerely,

      					H. Christopher Owings
      Assistant Director

cc: 	Jody Walker, Esq.
      Via Fax (303) 220-9902

Michael Enemaerke
Cross Atlantic Commodities, Inc.
December 6, 2005
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