SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

Mail Stop 6010								September 8,
2005

Susan Downing
President
Konigsberg Corporation
435 Martin Street
Suite 3220
Blaine, Washington 98230

Re:	Konigsberg Corporation
	Registration Statement on Form SB-2
      Filed August 15, 2005
	File Number 333-127571

 Dear Ms. Downing:

      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 note that where we provide examples to illustrate what
we
mean by our comments, they are examples and not exhaustive lists.
If
our comments are applicable to portions of the filing that we have
not cited as examples, make the appropriate changes in accordance
with our comments.
2. In your response letter, please state our comment and then
explain
each change that has been made in response to a comment.  In
addition, you should also reference each page number in which
disclosure has been revised in response to a comment so that we
can
easily place your revised disclosure in its proper context.

3. Please refer to Item 310(g) of Regulation S-B and file an
amended
registration statement on Form SB-2 to include your most recent
interim financial statements. In doing so, please also file as an
exhibit an updated, signed consent report from your independent
accountants.

Form SB-2
Risk Factors, p. 8
General
4. When disclosing a risk factor, you should customize it with
specific reasons why you may be exposed to a particular risk so as
to
make the disclosure more meaningful. As one example only, the
disclosure on page 5 in "If we do not obtain additional
financing...," you list a number of factors that can affect the
availability of financing in your industry, including market
prices
for mineral property and metals.  If you have reason to believe
that
the prices for these items could make it difficult for you to
obtain
financing, then you should state this fact explicitly rather than
generically referring to these market prices.

As another example, in "Because of the unique difficulties and
uncertainties...," you list a number of factors that may affect
the
company`s probability of success.  If you are aware of any facts
or
circumstances that suggest these factors may impact your
prospects,
you should disclose those facts in the risk factor.

Please review all of your risk factors to ensure that your
disclosure
is customized for the Company and is as specific as possible.  In
your response letter, please identify all places where revisions
are
made in response to this comment.

 "We have yet to attain profitable operations...," p. 5
5. Please disclose your accumulated losses as of June 30, 2005,
your
most recent quarter.
6. Please include the risks associated with your going-concern
opinion in a separate risk factor.

"Since this is an exploration project..., p. 5
7. It appears that the information contained in this risk factor
also
appears in other risk factors.  Please revise the disclosure to
explain the distinct risk that you are attempting to describe in
this
risk factor.

 "We have no known mineral reserves...," p. 6
8. We note your reference to having to cease operations.  However,
in
other sections of the registration statement, you indicate that
you
have no operations.  Please clarify.

"Because our president...," p. 7
9. Please describe what you have in mind when you say that "the
interests of Mrs. Downing may differ from the interests of other
stockholders."  What specific interests may differ and how do
those
differences represent a risk to investors?

Selling Stockholders, p. 8
10. If there are affiliates of broker-dealers identified as
Selling
Shareholders, please consider whether: (i) such Selling
Shareholder
purchased in the ordinary course of business and (ii) at the time
of
the purchase, such Selling Shareholder had no agreements or
understanding to distribute securities. If both (i) and (ii) are
true
for any affiliate, please include a representation to this effect
in
this section for that affiliate.  For any other affiliate, you
should
explicitly state that the affiliate is an underwriter.

Business, p.16
General
11. We note your reference to your relationship with WG Timmins.
Please file all reports that you have received (and all subsequent
reports that you receive prior to effectiveness) as exhibits to
the
registration statement.
12. Please also disclose WG Timmins` qualifications and experience
in
this field and the amount of any payments that you made to WG
Timmins
in connection with these reports.
13. In the subheading "Property Geology" on page 19, we note that
much of your information is quite technical.  As a few examples,
your
reference to "geanticline," "Karmutsen Formation," and "andesitic
to
balsaltic pillowed flows" may be confusing to investors that are
not
familiar with these terms.  Please expand your disclosure to
explain
what these terms mean and what these geologic characteristics
imply
for the possibility of successfully mining this property.

Report of Independent Registered Public Accounting Firm, page F-2

14. As your independent accountant`s report states that their
audit
was conducted in accordance with the "auditing standards" of the
PCAOB, as opposed to "the standards" of the PCAOB, please tell us
how
their report complies with paragraph 3 of PCAOB Auditing Standard
No.
1.  Based on the language used in the report, it is unclear
whether
the audit was conducted in accordance with the related
professional
practice standards of the PCAOB.  Otherwise, please provide us
with a
report that complies with paragraph 3, as revised by your auditor.

      As appropriate, please amend your filing 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 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 this action as 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.
      You may contact Amy Bruckner at (202) 551-3657 or Mary Mast
at
(202) 551-3613 if you have questions regarding comments on the
financial statements and related matters. Please contact Zafar
Hasan
at (202) 551-3653 or me at (202) 551-3715 with any other
questions.
      Sincerely,

      Jeffrey Riedler
   Assistant Director

cc:	Stephen O`Neill
	O`Neill Law Group PLLC
	435 Martin Street
	Suite 1010
	Blaine, WA 98230

??

??

??

??

</TEXT>
</DOCUMENT>