SecProbe.io

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Mail Stop 0610					October 27, 2005

Mr. David A. Walker
President
Enable IPC Corporation
25030 Avenue Stanford, Suite 240
Valencia, California 91355

Re: Enable IPC Corporation
      Registration statement on Form SB-2
     Amendment no. 1 filed September 30, 2005
     File no. 333-125504

Dear Mr. Walker:

      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.

"If we do not raise additional capital....," page 5

1.   We note your response to comments 16-18 and the related
revisions in the prospectus and Item 26 of the registration
statement.  Please provide a detailed analysis concerning why the
unregistered sales of securities should not be integrated with the
registrant`s proposed public offering.  Please include a
description
of the facts and circumstances of each respective sale.  We may
have
additional comments.

Financial Statements, page 53

3.  Intangible Assets, page F-11

2.   Regarding your response to prior comment sixty, please
address
the applicability of and your compliance with specific paragraphs
of
APB 29, SFAS 2, FIN 4, SFAS 5, SFAS 123, SFAS 142, and any other
relevant literature.  In so doing:

* Please tell us why your "conservative approach" is appropriate,
especially as you believe that the fair value of the patent
application exceeds the amount your recognized.  In this regard,
even
if "a conservative approach" was appropriate, it is unclear how
subsequently recognizing less amortization expense is
conservative.
In addition, please clarify why you did not appear to regard the
present value of the minimum annual royalty payments as
consideration
that could have provide a basis for determining the fair value of
the
patent application.

* Please tell us the business reasons for the minimum annual
royalty
payments, including the extent to which they served as a financing
mechanism, and any circumstances where you would not have to pay
them.  In addition, please justify your belief that they should
not
have been recognized as a liability.  Furthermore, please tell us
whether the present value of the minimum annual royalty payments
should have reduced the amount attributed to the stock issued and
why

4.  Common Stock, page F-11

3.   Please provide us the itemized schedule that you said, in
response to prior comment 62, was enclosed, as we do not see where
it
was enclosed

General

4.  We note your responses to comments 3 and 40, however we have
not
received the requested supplemental information referred to in
your
correspondence.  Please provide this information as soon as
practicable.  We may have additional comments subsequent to our
review.

      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 supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR under the form type label CORRESP.
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.

      You may contact Ibolyla Ignat at (202) 551-3656 or Oscar
Young
at (202) 551-3622 if you have questions regarding comments on the
financial statements and related matters.  Please contact John L.
Krug at (202) 551-3862 or me at (202) 551-3710 with any other
questions.

      Sincerely,

      Jeffrey Riedler
      Assistant Director

cc: Cathryn S. Gawne, Esq.

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