SecProbe.io

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      January 24, 2005

Brent Peters
President
High Tide Ventures, Inc.
747 17th Street, Suite 301
West Vancouver, British Columbia
Canada V7V 3T4

Re:	High Tide Ventures, Inc.
	Registration Statement on Form SB-2
      Filed December 22, 2004
	File No. 333-121542

Dear Mr. Peters:

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

Outside Front Cover of Prospectus - Page 3

1. Please note that the number of shares being offered indicated
on
the outside front cover of your prospectus does not match the
amount
of shares being registered by your registration statement, as
indicated on your registration fee table and your table of selling
shareholders.  Please revise the front cover of your prospectus to
reflect the correct number of shares being offered.

Summary - Pages 5 to 6

2. We note your use of industry terms such as "economic reserves,"
"economic mineralization," and "economic mineral deposit."  Please
revise your disclosure so that the meaning of these terms can be
understood by investors who are not familiar with your industry.

3. We note that your prospectus summary only indicates that your
objective is to conduct mineral exploration activities for gold,
whereas other sections of your prospectus refer to one or more of
copper, zinc, silver and/or gold.  Please revise your prospectus
so
that your disclosure in this regard is consistent throughout your
prospectus and update your prospectus summary accordingly.

4. Please indicate in your summary that your auditors have
concluded
that there is substantial doubt that your company will be able to
continue as a going concern and that in all likelihood you will
need
to raise additional funds within the next twelve months.

Description of Business - Pages 19 to 24

	In General - Page 19

5. We note your disclosure that you will be "engaged in the
acquisition ... of mineral properties."  If your business plan
includes acquiring properties or mineral claims in addition to the
Sparta Property, please clarify that this is your strategy and
include any material risks to your business and operations related
to
that strategy in your "Risk Factors" section.

Plan of Operations - Pages 24 to 25

6. We note that your total expenditures over the next 12 months
are
expected to be approximately $35,000 and that as of December 22,
2004
you had $14,982 in cash.  As such, please indicate how long you
will
be able to satisfy your cash requirements and specify that you
will
have to raise additional funds within the next twelve months in
order
to effect your plan of operations.  Refer to Item 303(a)(1)(i) of
Regulation S-B.

7. Please revise to provide more details of the specific plan of
operations, the expected timing to commence exploration on the
Sparta
property, and the expected funding needs and sources.  In
addition,
revise your discussion to address what will happen if you are
unable
to obtain the necessary additional funding.

Description of Property - Page 25

8. Please revise to disclose the material terms of any agreement
or
arrangement under which the company occupies the premises from
which
it conducts its business operations.  For example, we note that
the
company has indicated that its principal executive offices are
located on 17th Street in West Vancouver, B.C.

Executive Compensation - Pages 26 to 27

9. Please update your summary compensation table to include the
information specified in Item 402(b)(2) of Regulation S-B for your
fiscal year ended December 31, 2004.  Please also make
corresponding
changes to the introductory paragraph to your table.

Financial Statements

General

10. Please update the financial statements, if necessary, as
required
by Item 310 of Regulation S-B.

11. Include an updated accountant`s consent with all amendments to
the filing.

Note 1. Nature and Continuance of Operations

12. We note your discussion regarding the Company`s ability to
continue as a going concern.  Please revise to include a detailed
discussion of the Company`s viable plan of operations, including
your
anticipated exploration funding program and expected costs,
financing
needs and sources of financing in accordance with FRC 607.02.  The
specific plans to address the threat of the going concern issues
and
the plans to resolve the doubts about the entities continued
existence should also be discussed.

Note 2. Summary of Significant Accounting Policies
g) Environmental Costs

13. We note that environmental expenditures are "charged to
operations or capitalized as appropriate".  Please revise to
disclose
your basis for determining the appropriateness of expensing versus
capitalizing environmental expenditures.

Note 3. Loans Payable

14. Please revise to accrue all costs of doing business for all
periods, including interest on the non-interest bearing loan and
any
other services, equipment or property provided without charge as
required by SAB Topic 1.B.1.

Note 4. Common Stock

15. Disclose details of each of the stock issuances in the
financial
statements, including whether these were issued to related parties
and how the prices were determined. Please disclose details of the
accounting treatment if any of these were issued for services.

Exhibit 5.1 - Legality Opinion

16. We note the first paragraph of the opinion refers to 30
individual shareholders but that your disclosure on page 17 refers
to
32 stockholders and that your disclosure on page 25 refers to 29
shareholders.  Please revise the prospectus disclosure, and the
opinion, so that these numbers are consistent.

17. Given the limitation in the last paragraph, that the opinion
is
"as of the date hereof," please file a signed legal opinion which
does not contain this limitation or which is dated as of the date
you
intend to go effective.

Engineering Comments

General

18. For your property, provide the disclosures required by
Industry
Guide 7 (b).  In particular, provide:
* The location and means of access to the property.
* Any conditions that you must meet in order to obtain or retain
title to the property.
* A brief description of the rock formation and mineralization of
existing or potential economic significance on the property.
* A description of the present condition of the property.
* A description of any work completed on the property.
* A description of equipment and other infrastructure facilities.
* The current state of exploration of the property.
* The total cost of your property incurred to date and planned
future
costs.
* The source of power that can be utilized at the property.
* If applicable, provide a clear statement that the property is
without known reserves and the proposed program is exploratory in
nature.
Refer to Industry Guide 7 (b) (1)-(5) for specific guidance.
Industry Guide 7 can be reviewed on the Internet at
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7.

19. Insert a small-scale map clearly showing the location and
access
to your property with an index map showing where the property is
situated in relationship to a political boundary (i.e. the state
or
province, etc., in which it was located).  Note that SEC`s EDGAR
program now accepts digital maps, so please include these in any
future amendments that are uploaded to EDGAR.  It is relatively
easy
to include automatic links at the appropriate locations within the
document to GIF or JPEG files, which will allow the figures and/or
diagrams to appear in the right location when the document is
viewed
on the Internet.  For more information, please consult the EDGAR
manual, and if you need addition assistance, please call Filer
Support at 202-942-8900.  Otherwise, provide the map to the staff
for
our review.

Risk Factors - Page 6

20. Add a risk factor that addresses the fact that your property
has
not been examined in the field by a professional geologist or
mining
engineer, detail the risks to investors.

Description of Business - Page 19

21. Discuss the phased nature of the exploration process, and the
place in the process your current exploration activities occupy.
Disclose that you will make a decision whether to proceed with
each
successive phase of the exploration program upon completion of the
previous phase and upon analysis of the results of that program.

22. Make it clear to investors that even if you complete your
current
exploration program and it is successful in identifying a mineral
deposit, you will have to spend substantial funds on further
drilling
and engineering studies before you will know if your have a
commercially viable mineral deposit, a reserve.

Title to the Sparta Property - Page 20

23. Disclose:
* The nature of your ownership or interest in the property.
* Any other underlying agreements or interests in the property.
* Provide names, claim, or grant number, date of recording and
expiration date, so your claims can be distinguished from other
claims in the area.
* Disclose the conditions you must meet to keep these claims.
* Disclose the area of your claims, either in hectares or acres.
Revise to fully discuss the material terms of your land or mineral
right securing agreements.  Refer to paragraph (b) (2) of Industry
Guide 7.

Exploration History - Page 21

24. The first paragraph refers to the nearby Discovery mine.
Describe only geology, history, or exploration results that are
directly related to the properties that you have the right to
explore
or mine.  Remove all references to mines, adjacent or analogous
properties, deposits, occurrences, or exploration activities by
other
companies outside of your properties.

25. The third paragraph references a report filed with the
Canadian
Government.  This report estimates a tonnage and grade associated
with this claim, without defining the data quality as a resource
or
reserve estimate.  We note that "mineral resources" must have
"reasonable prospects for economic extraction."  For both
operating
mines and undeveloped properties, we believe this means that any
reportable "resource" estimates must be delimited using an
economically-based "cutoff" to segregate "resources" from just
"mineralization."  Based on the information supplied to date, this
resource statement only provides an estimate of geologically
available mineralization, and does not appear to be related to
current economic conditions at the property.  An economic cutoff
should enable a mine to distinguish materials that can at least
cover
the mine`s operating costs from those that will not.  Your
"resource"
cutoffs do not appear to do this, and therefore do not meet the
economic aspects of the definition for "resources."  Remove all
resource estimates, which are not based on an economically derived
cutoff.  If you choose to provide us with revised estimates of
resources based on an economic cutoff, supplementally provide
backup
calculations and information sufficient to support your
conclusion.

Geologic Assessment Report - Page 21

26. Expand your disclosure about your exploration plans for your
properties.
* Disclose a brief geological justification for each of your
exploration projects written in non-technical language.
* Give a breakdown your exploration timetable and budget,
including
estimated amounts that will be required for each exploration
activity, such as geophysics, geochemistry, surface sampling,
drilling, etc. for each prospect.
* If there is a phased program planned, briefly outline all
phases.
* Alternatively, disclose that you have no current detailed plans
to
conduct exploration on your property.
* Disclose how the exploration program will be funded.
* Identify who will be conducting any proposed exploration work,
and
discuss what their qualifications are.
      If there are any questions concerning the above Engineering
comments you may contact George Schuler, Mining Engineer at (202)
942-5527.

* * *

      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 supplemental 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.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the
United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Lynn Dicker at (202) 824-5264, or Brian
Cascio,
Branch Chief, at (202) 942-1791, if you have questions regarding
our
comments on the financial statements and related matters.  Please
contact Tim Buchmiller at (202) 824-5354 or me at (202) 924-
7924with
questions regarding our comm