SecProbe.io

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20549-0408

                                    March 23, 2005

Perry Augustson, President
Triton Resources, Inc.
7363 146 A Street
Surrey, British Columbia
Canada, V3S 8Y8

Re: Triton Resources, Inc.
       Form SB-2, amendment number 1, filed March 11, 2005
       File Number 333-122039

Dear Mr. Augustson:

      We have given a full review to your amended Form SB-2 and
have
the following comments.  Where indicated, we think this document
should be revised in response to our 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 have
additional
comments.

      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.

Prospectus Summary - page 4

1. In any amendment delete the term "further" from the second
paragraph.  Prominently disclose that to your knowledge no one has
been to the property, including Mr. Burjoski.

2. In any amendment disclose any affiliation between Mr. Burjoske
and
Mr. Augustson, or state that there is none.

Financial Statements
Note 2 (i) Foreign Currency Translation - page F-46

3. We note your response to prior comment 23.  The disclosures in
your document suggest that you should use the Canadian dollar as
your
functional currency.  Paragraph 5 of SFAS 52 states that an
entity`s
functional currency is the currency of the primary economic
environment in which the entity operates; normally, that is the
currency of the environment in which an entity primarily generates
and expends cash.  The following items indicate that your
functional
currency is the Canadian dollar:

* Labor, material and other costs of your exploration plan are
primarily local costs in Canada and are expressed in Canadian
dollars
in your Plan of Operation.
* Through the date of the financial statements, cash has been
generated solely through the issuance of shares and each
shareholder
appears to be a resident of Canada.

Please reconsider the determination of your functional currency.
Should you determine the functional currency is the Canadian
dollar,
restate your financial statements to report translation
adjustments
in other comprehensive income.  Refer to paragraph 13
of SFAS 52.

						* * * * *

      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.

      Direct any questions on accounting matters to Heidi Berg, at
202-824-5463 or to Donald Walker, Senior Assistant Chief
Accountant,
at 202-942-1799.  Please direct any other questions to David Lyon
at
202-942-1796, or to me at 202-942-2889.

      						Sincerely,

							William C-L Friar
      Senior Financial Analyst

By fax : Joseph I. Emas
	  Fax number 305-531-1274

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Triton Resources, Inc.
Page 3

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