SecProbe.io

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Room 4561

      June 13, 2005

Mr. Alexander Vesak
American Media Systems Co.
3500 Cornett Road
Vancouver, British Columbia, V5M2H5

      RE:	American Media Systems Co.
   Amendment No. 2 to Registration Statement on Form SB-2
   Filed June 2, 2005
   File No. 333-123169

Dear Mr. Vesak:

      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.  After reviewing this information, we may or may not
raise additional comments.  Feel free to call us at the telephone
numbers listed at the end of this letter.
Prospectus Summary, page 3
1. While we note that you provided updated financial statements
with
this amendment, you should revise throughout your filing to
provide
similar updated disclosure.  For example, please revise your
summary
of financial data table to include information as of and for the
most
recent financial statement period that is included in the
registration statement and revise the dilution disclosures to
present
book value as of the date of the most recent balance sheet.  In
addition, your "Management Discussion and Analysis or Plan of
Operations" section should be updated to include a discussion of
the
results of operations for the most recent period for which
financial
statements are presented.  Further, ensure that other information
throughout the filing, including the amounts discussed in your
"Description of Securities" section, is appropriately updated as
well.
Risk Factors

Our President is our sole director and executive officer ..., page
5
2. While we note that you added this risk factor in response to
comment 3 of our letter dated May 17, 2005, please revise the text
of
the risk factor to include a discussion regarding Mr. Vesak`s
responsibility for establishing and monitoring his own internal
controls over financial reporting and disclosure controls and
procedures.

Plan of Distribution, page 8
3. In light of your response to comment 7 of our letter dated May
17,
2005, please revise your Prospectus Front Cover and "Prospectus
Summary" section to prominently indicate that Mr. Vesak may
purchase
unlimited securities in order to achieve the minimum offering
amount.
Further, please provide separate risk factor disclosure to discuss
the ramifications to investors of Mr. Vesak purchasing unlimited
shares in order to achieve the minimum amount.  For example, we
would
expect to see prominent disclosure of the risk that the offering
could result in only a small number of unaffiliated investors
owning
stock in the company.
Description of Business

Marketing Plan, page 14
4. While we note the revisions you have made in response to
comment 8
of our letter dated May 17, 2005, please revise to clarify whether
the costs you expect to incur in securing additional agency
agreements have already been included in the "Travel" and "Rent
and
General Legal and Office Expenses" amounts you have provided in
the
use of proceeds table on page 7, and in the related marketing plan
discussion in this section.

Signatures
5. Please note that the registration statement must be signed by
the
registrant, as well as by its principal executive officer,
principal
financial officer, principal accounting officer or controller and
a
majority of its directors.  While we note that your registration
statement is signed by all of the necessary individuals, it has
not
been signed by the registrant.  Please ensure that your next
amendment is appropriately signed and dated.  See the signatures
section of Form SB-2.
Exhibits
6. Please provide a more recently dated legality opinion from
counsel.

* * * * *

	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 Rule 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 Brian Bhandari, at (202) 551-3390 if you
have
questions regarding comments on the financial statements and
related
matters.  If you have any other questions please call Adam Halper,
at
(202) 551-3482, Sara Kalin, at (202) 551-3454 or the undersigned,
at
(202) 551-3462.  If you need further assistance, you may contact
Barbara Jacobs, Assistant Director, at (202) 551-3730.

								Sincerely,

								Mark P. Shuman
								Branch Chief-Legal

cc:	Via Facsimile
      Conrad C. Lysiak, Esq.
	601 West First Avenue, Suite 503
	Spokane, Washington 99201
	Telephone: (509) 624-1475
	Facsimile:  (509) 747-1770
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Mr. Alexander Vesak
American Media Systems Co.
June 13, 2005
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