SecProbe.io

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							March 16, 2005

     Mail Stop 0510

Stanley Major
Major Creations Inc.
57113, 2020 Sherwood Drive,
Sherwood Park, AB, Canada, T8A 5L7

Re: 	Major Creations Inc.
	Form SB-2
	Filed February 17, 2005
	File Nos. 333-122870

Dear Mr. Major:

      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.

General

1. Please revise to explain in more detail how your founders,
officers and directors became engaged in your proposed business to
retail vintage styled small diesel compact tractors.

Prospectus Cover Page

2. Briefly state here the purpose of this public offering and your
reasons for choosing this manner of financing your operations.

Risk Factors, page 5

3. Please add a risk factor discussing that management will have
broad discretion in allocating any offering proceeds.

4. Please add a risk factor that addresses the fact that your
officers and directors will own a majority of your common stock
after
the offering, which would impact shareholders` ability to affect
corporate change.

Volume of Sales May Be Insufficient. . . page 5

5. We note your statement that you anticipate a gross profit
margin
of less than 10%.  Please explain to us your basis for this
statement.  Also, please explain your statement in the next risk
factor that you may be required to sell your product with a gross
profit of less than 5%.

Item 8. Plan of Distribution, page 10

6. You state that your officers and directors intend to contact
people they know from previous business relationships "in
connection
with their efforts to sell the securities offered by this
prospective
(sic)."  What do you mean by "previous business relationships" and
"in connection with"?  Please more fully disclose your plan of
distribution in accordance with Item 508(c) of Regulation S-B.
Describe the officers` and directors` anticipated selling efforts.
To whom will they market the shares?  What we are looking for is a
more a detailed explanation of how the individuals will undertake
their selling efforts.  Please advise us supplementally if you
intend
to directly market the shares to potential customers, friends,
etc.?
How do they plan to market the shares?  For example, will they
personally solicit people or conduct a mass mailing?

7. In addition, you state that you may employ services of an agent
or
intermediary.  Have you entered into any agreements with agents,
finders or intermediaries?  Please advise us supplementally.  We
may
have further comment based on your response.

Item 13. Interest of Named Experts and Counsel, page 13

8. We note your statement that Alexander H. Walker, III, has
issued
an opinion on the validity of the shares offered by this
prospectus,
which has been filed as an Exhibit to this prospectus with Mr.
Walker`s consent.  Please file this opinion with your next
amendment.
Also, please provide the address of counsel who will pass on the
validity of the securities covered by your registration statement.
Please refer to paragraph 23 of Schedule A to the Securities Act.

Item 16. Description of Business, page 14

Competition and Competitive Strategy, page 15

9. We note your statements that there are numerous sellers of new
lawn and garden compact tractors and mowers and that several
individuals in Western Canada are restoring antique tractors.
Please
revise this section to provide a better idea of your industry and
its
competitive conditions.  Clarify whether you face competition in
your
particular business niche.  If so, please disclose whether and how
many competitors you have that refurbish new tractors to provide
an
antique look, their geographic location, names, years in the
business, and percentage of the market.

Distribution, page 15

10. We note your intention to use your planned web site to promote
your products.  Please disclose whether this web site will enable
order processing or simply provide information about your product.

11. Please disclose your distribution methods and their costs.
For
instance, disclose whether you will ship your tractors to
customers
or have them retrieved at your facilities.

Sources and Availability of Products and Supplies, page 15

12. We note that you have identified certain suppliers of tractors
in
Canada and internationally and assessed the cost effectiveness of
purchasing from each.  Please provide a more detailed discussion
of
the costs and benefits of the different supplying options.

13. Please disclose the sources of the add-on products to be used
in
your design process and the availability of supply.

Employees, page 16

14. We note that your employees will be responsible for all duties
in
your business plan.  To the extent practicable, describe the
duties
that each of your officers and directors will undertake in
furtherance of your business plan.  In this regard, we note that
one
of your expenditure line items in the plan of operations is for
consultation and training with industry experts.  Discuss each
employee`s experience with the manufacturing process contemplated
by
your plan of operation and the level of training and consultation
you
anticipate will be necessary.

Item 17. Plan of Operation, page 16

15. Please discuss your plan of operations for the next twelve
months
in greater detail as required by Item 303(a) of Regulation S-B.
Include more detailed milestones to your business plan, taking the
company to the point of generating first revenues, the costs
associated with each milestone, and the employees responsible for
each aspect of the business plan.  Currently, it appears that your
plan of operations assumes you raise the maximum amount in this
offering.  Please revise the disclosure to indicate the impact on
your plan of operations if you raise less than the maximum amount
in
this offering and fail to raise additional funds by other means.

16. Please provide a basis for your belief that it will take 2-3
months to raise funds in this offering necessary to effectuate
your
business plan.

17. Because you believe it will take 2-3 months to raise the funds
necessary to complete your business plan, please reconcile this
with
your desire to be ready for the spring farms shows starting in
late
March.

18. We note your statement that with the purchase of four tractors
you would be considered a dealer by the manufacturer and so would
be
able to pass on the manufacturer`s warrantee to your customers.
Please disclose the basis for this expectation.  For instance,
would
you be required to enter into a separate agreement with the
manufacturer or is the purchase of a certain number of tractors
contemplated in the warrantee?  Please clarify this point.

19. Because your proposed web site will be a means to promote your
business, please disclose whether the costs of web site
development
and/or marketing listed in your table include those costs
associated
with web marketing.  For instance, discuss any plans and costs
involved with listing your site with internet search engines.
Also,
disclose whether customers will be able to place orders through
your
site.

20. We note that rather than purchasing the tools and machines
yourselves, you will have wheel modification done in a machine
shop
for the first year.  Please identify the third party shop you will
be
using and clarify the role your employees will play in wheel
modification, if any.  If you have entered into an agreement with
this third party shop, please file that agreement or tell us why
the
agreement does not constitute a material agreement.

Expenditures, page 18

21. Please explain the first and second charts in this section.
Do
the totals assume raising a certain amount below the maximum
offering
proceeds?  Please reconcile this with the line items in your use
of
proceeds table.  For instance, marketing and promotion is
estimated
at $2,000 in your first chart but $3,000 in your use of proceeds
table under a 25% scenario.

Signatures

22. Your chief accounting officer or controller must sign the
registration statement and be identified on your signature page.

Closing Comments

      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 that is filed on EDGAR 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.

     Please contact Craig Slivka, Staff Attorney at (202) 942-
7470,
or in his absence Lesli Sheppard, Senior Staff Attorney, at (202)
942-1887 with any other questions.

     					Sincerely,

      			Pamela A. Long
      			Assistant Director

cc:	W. Scott Lawler, Esq.
      1530-9 Avenue SE
      Calgary, AB T2G 0T7
	(403) 272-3620
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

         DIVISION OF
CORPORATION FINANCE

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