SecProbe.io

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Mail Stop 3561

November 16, 2005

Irene Braham, President
Homassist Corporation
107-1520 McCallum Road, Suite #29
Abbotsford, British Columbia, Canada V2S 8B2

        RE:  Homassist Corporation ("the company")
                Amendment No. 2 to Registration Statement on
                Form SB-2
                Filed October 11, 2005
                File No.  333-124405

Dear Ms. Braham:

We have reviewed your amended 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.

Prospectus Summary, page 4
1. We reissue prior comment three in the letter dated August 29,
2005.  We again refer to the statement that "we do not expect to
have
revenues until at least three months after this registration
statement becomes effective."  Please explain the basis or remove.

Irene Braham
Homassist Corporation
November 16, 2005
Page 2.

Distribution, page 17

2. Here or in another appropriate section, please disclose the
proposed charges for each service contemplated being offered by
the
company.  For example, what will the company charge each
participant
for attending a community seminar, a classroom or private
tutorial?
3. Also, here or in another appropriate section, please discuss
the
company`s plans to sell products such as those that will be used
in
the training to be conducted, such as health care products,
walkers,
canes, specialty cutlery, support belts, shower supports and
rails,
etc.  We note the statement under "Marketing and Promotions",
"[I]t
will include the printing of our information brochure and the cost
of
seminars to assist us in creating a market for our services and
products."

Government Controls and Approvals, page 18
4. In the penultimate paragraph, please provide the basis for the
statement, "[A]s Homassist will not be giving any medical or
diagnostic advise or evaluations, there are no licensing or
certification requirements for the individuals providing
training."

Reports to Security Holders, page 18
5. Please update to provide the current address for the SEC which
is:
100 F Street, N.E.    Room 1580   Washington, D.C.  20549.

Irene Braham
Homassist Corporation
November 16, 2005
Page 3.

Item 17.  Plan of Operation

Expenditures, page 21

6. We note the statements in the penultimate paragraph, "[I]f we
fail
to raise at least $15,000 of the $60,000 we are seeking from this
offering, then we will have to find other methods to raise
additional
funds.  At this time, there are no anticipated sources of
additional
funds in place."  Please expand to address in some specificity
what
will happen in the event $15,000 is not raised in this offering.
We
note that any investors who have already bought into this offering
will not be able to have their funds returned.
7. Please provide the basis for the statement in the final
paragraph,
"[W]e are confident we can meet our financial obligations and
pursue
our plan of operations if we can raise the maximum amount of
funding
as contemplated by this Offering and begin collecting revenue from
operations within the first year of this prospectus becoming
effective."
8. Please update the cash balance as of the most recent
practicable
date and discuss how long you can currently satisfy your cash
requirement.
9. Clarify what you mean by the statement that the directors of
Homassist are committed to the project.  Have they agreed to
provide
funding in the case this offering only raises nominal funding?
Explain how they will continue with the development of the
business
and how they will obtain the necessary funding.  We may have
further
comment.
10. Please disclose whether or not officers and directors have
committed to buying any shares in this offering, and if so, please
disclose the amount they have committed to.  Is there any
definitive
agreement?

Irene Braham
Homassist Corporation
November 16, 2005
Page 4.

Certain Relationships and Related Transaction, page 21

11. Regarding the language added on page 21 with respect to our
prior
comment 22 in the letter dated August 29, 2005, please name the
promoters as required by Item 404(a) of Regulation S-B.  These
individuals should be clearly listed as promoters, rather than
"may
be deemed to be promoters."

Part II.

Item 26.  Recent Sales of Unregistered Securities, page 25

12. Please discuss the sophistication of investors and state
whether
they had access to information.  See Rule 504(b)(iii) of
Regulation D
in this regard.

Interim Financial Statements @ 7/31/2005
Balance Sheet, page F-2

13. Revise to correct the amounts for cash, accumulated deficit
and
related totals at July 31, 2005.

Statement of Loss, page F-4

14. The amounts in the columns labeled "July 15, 2004 (date of
incorporation) to July 31, 2004" are duplicative of the
corresponding
amounts in the next-to-last column.  Please delete one of the two.
Also, revise to delete the quarterly statements of operations for
the
three months ended June 30, 2005, since interim financial
statements
are only required for the year-to-date periods by Item 310(b) of
Regulation S-B, as well as any cumulative periods required by SFAS
7.

Statement of Stockholders` Equity, page F-8
15. Revise to include the net loss for the period ended July 31,
2005.

Irene Braham
Homassist Corporation
November 16, 2005
Page 5.

General

16. For future amendments, please provide a letter which clearly
addresses each of the staff`s comments, indicating where the
change/addition/deletion was made, and providing any other
informative data pertaining to the comment.

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
with your amendment that keys your responses to our comments and
provide 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 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 Donald Wiland at (202) 551- 3392 with any
questions
regarding accounting issues and you may contact Janice McGuirk at
(202) 551-3395 with any other questions.

Sincerely,

John Reynolds

Assistant Director

CC:   W. Scott Lawler, Esq.
          (403) 272-3620 via fax

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