SecProbe.io

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Mail Stop 6010

								June 10, 2005

James Tubbs
President and Chief Executive Officer
Sports Source, Inc.
421 Seventh Avenue, 14th Floor
New York, NY 10001

	Re:	Sports Source, Inc.
		Registration Statement on Form SB-2
		Filed May 23, 2005
		File No. 333-125131

Dear Mr. Tubbs:

	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
information so we may better understand your disclosure.  After
reviewing this information, we may 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 SB-2

Prospectus Cover Page

1. Currently, you provide the penny stock disclosure in three
different places: on your prospectus cover page, in a risk factor
on
page 5, and on page 6.  Please eliminate the repetition.
Typically,
this information is not on the cover page, but if you choose to
leave
it there, you do not need to repeat elsewhere.

Risk Factors, page 2

2. We note from page 12 that you do not plan to pay dividends.
Please include a risk factor stating that any profit from an
investment in your company will need to come from an increase in
share value.

We will require financing to achieve . . . , page 3

3. Please discuss the adverse effects of raising funds, such as
dilution, in a separate risk factor.

Our success depends upon our ability to attract and hire key
personnel . . . , page 4

4. If you have had any material difficulties attracting and hiring
key personnel, please disclose that fact and discuss the
situation.
Also, if you have limited experience in recruiting key personnel,
you
should disclose that fact.

The offering price of the shares was arbitrarily determined . . .
,
page 5

5. We note the reference to Source Atlantic, Inc.  As this is the
first and only time Source Atlantic is mentioned in the document,
please explain who that company is and how its value affects your
stock`s value.  Alternatively, if this reference was included by
accident, please delete it.

Directors, Executive Officers, Promoters and Control Persons, page
9

6. Please disclose Mr. Tubbs`s business experience during the past
five years, and include the dates when he served in each position.

Description of Business, page 13

7. Please define fantasy sports.  Also, please explain how you
anticipate the fantasy sports concept will enable you to generate
revenue and ultimately a profit.  Finally, please explain what
incentives you intend to provide to encourage or what motivational
factors you expect will operate to cause people to play your
fantasy
sports games.

8. We note you will launch the second stage of your operations
"[a]s
the site grows its user base and reputation within the industry."
On
page 16, you estimate you will launch the second phase in 2006,
but
you state it will depend on how quickly you are able to develop a
user base.  Please give a more specific, objective explanation of
how
you will determine it is time to launch the second phase of your
business plan.  For example, specify the approximate number of
users,
the number of daily visits to the site, the amount of revenues, or
other indications that will trigger the launch of the second
phase.

9. We note the statement that your website presently offers sports
headlines, news stories by sports, sports scores, links and
reviews
for leading online fantasy games, game lines, a message forum, and
tickers with news and scores.  Although we can see the links to
leading games, we are unable to locate the reviews for these
games.
Also, we are unable to locate the game lines and message forum.
If
these features are operational on your website, please tell us how
we
can locate them.  If they are not yet operational, please revise
your
filing to clarify this fact.

10. Where you identify on page 14 classified ads fees as a
potential
source of revenue, please disclose what type of classified ads you
expect to be able to list on your webpage.

Management Discussion and Analysis, page 16

11. On page 17, you state you have enough funds to satisfy minimum
cash requirements over the next twelve months.  It is unclear what
"minimum cash requirements" means.  Instead of using this term,
please provide your best estimate in each bullet of what you will
need in 2005 and 2006, as applicable, for the activities described
in
that bullet and then provide in the last paragraph an aggregate
amount you will need in 2005 and 2006.

Description of Property, page 17

12. We note that you are currently being provided with office
space
at no charge to the company.  All costs of doing business should
be
reflected in your historical financial statements.  Please refer
to
SAB 1B.1.

13. Please identify the property owner who provides the office
space
to you at no charge.

Signatures, page 26

14. Your controller or principal accounting officer is required to
sign the registration statement, and the signature should include
a
caption stating this title.  We presume this individual is Mr.
Tubbs.
Therefore, please add the title of "controller" or "principal
accounting officer" to Mr. Tubbs`s signature.  See Instructions 1
and
2 to the Signatures section of Form SB-2.

Financial Statements, page 2

15. Please provide updated audited financial statements and
financial
information for a period within 135 days of filing your initial
registration statement.  Refer to Rule 3-10(a) of Regulation S-B.

Note 6. Going Concern, page 8

16. Please clarify what actions are presently being taken to
obtain
additional funding and implement its strategic plans.

*	*	*

	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.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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 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 Sasha Parikh at (202) 551-3627 or Mary Mast
at
(202) 551-3613 if you have questions regarding comments on the
financial statements and related matters.  Please contact Greg
Belliston at (202) 551-3861 or me at (202) 551-3715 with any other
questions.

								Sincerely,

								Jeffrey Riedler
								Assistant Director

cc:	Gregg E. Jaclin, Esq.
	Anslow & Jaclin, LLP
	195 Route 9 South, Suite 204
	Manalapan, NJ 07726
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James Tubbs
Sports Source, Inc.
June 10, 2005
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