SecProbe.io

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November 29, 2005

Mr. Jay Mumford
Division of Corporate Finance
U.S. Securities & Exchange Commission
Mail Stop 0603
Washington, D.C.  20549

         Re:      Wimax EU, Ltd
                  Amendment No.3 to Registration Statement to Form SB-2
                  Filed October 21, 2005
                  File No. 333-123351

Dear Mr. Mumford:

We represent Wimax EU, Ltd ("Wimax" or the "Company"). We are in receipt of your
letter dated  November 2, 2005  regarding  the above  referenced  filing and the
following are our responses:

     1.   Please refer to our prior  comment 11 from our letter dated  September
          13, 2005 regarding your outstanding shares having apparently  exceeded
          your  authorized  shares at December 31, 2004.  It is unclear how this
          does not result in you issuing shares that were not authorized. Please
          explain.

  Answer: Please note that all  stockholders  of record who owned  greater  than
          2,001 shares of the Company's common stock agreed to waive their right
          to receive  shares  pursuant to the 5 for 1 forward split  effected on
          February 15, 2005.  Accordingly,  each of such  shareholders  signed a
          Shareholder  Waiver  Agreement dated February 14, 2005 which have been
          included in this amended SB-2 as exhibits.  Pursuant to such  waivers,
          these  shareholders were not issued shares pursuant to the stock split
          as they had relinquished all rights to such shares.  Accordingly,  the
          Company  has  amended  its  financial  statements  for the year  ended
          December 31, 2004 and for the quarter  ended  September 30, 2005 so as
          to not apply  the  forward  split to the  shares  held by the  waiving
          shareholders.  Therefore, the revised financial statements reflect the
          accurate number of shares  outstanding  which do not exceed the number
          of shares authorized.  In addition, the financial statements have been
          revised  to treat  the  common  stock  split as a stock  dividend  for
          accounting  purposes,   as  the  stock  split  did  not  result  in  a
          corresponding decrease in the par or stated value per share.

          Additionally,   please  note  that  in  the  Company's   prior  letter
          responses,  it was stated  that no waivers  existed.  Please note that
          such statement was incorrect. The waivers were executed by the waiving
          shareholders on February 14, 2005; however, the Company decided not to
          use such waivers and to treat the waiving  shareholders for accounting
          purposes as having  retired  their  shares as an in-kind  contribution
          back to the Company. Although such shares were never in fact issued to
          the waiving shareholders who in fact had no right to such shares, this
          accounting  application  had the  effect  of  presenting  more  shares
          outstanding   than  were   authorized  in  the   Company's   financial
          statements.  Therefore,  the Company has  accepted  the  shareholder's
          waivers and  corrected  the  financial  statements  for the year ended
          December  31, 2004 and for the  quarter  ended  September  30, 2005 to
          accurately  reflect that the waiving  shareholders  had in fact waived
          their right to the forward split shares and that the forward split did
          not apply to the  waiving  shareholders.

     2.   Please reconcile the exercise prices of the stock options mentioned on
          pages 13 and 14.

  Answer: The SB-2  has been  amended to  correctly  reflect the  exercise price
          of $0.50 for the stock options held by Christopher Lee Miles.

ANSLOW & JACLIN, LLP

BY: /s/ GREGG E. JACLIN
   -------------------
   GREGG E. JACLIN

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