SecProbe.io

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Mail Stop 6010									October 6,
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.

Risk Factors, p. 8
Because our president..., p.9
1. We note your response to prior comment 9 relating to the
possibility that the company president may have interests that
differ
from minority stockholders.  In addition to the language
referencing
amendments to the articles of incorporation, please consider
including the possibility that (i) corporate combinations or
similar
transactions that might benefit minority stockholders may be
rejected
by the controlling stockholders to their detriment and (ii) the
company president may have control over transactions between her
and
the company.

In addition, as currently written, your disclosure states that the
company president may be able to "significantly influence"
decisions.
Please revise this phrase to state that she will be able to
"control"
theses decisions.

Selling Stockholders, p. 8

2. We note your response to prior comment 10 stating that none of
the
selling shareholders or their affiliates are broker-dealers.
However, this is different from saying that none of the selling
shareholders are affiliates of broker-dealers, which our comment
addressed.  Accordingly, we are reissuing the comment.

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

3. We acknowledge your response to comment 14 per our letter dated
September 8, 2005. We note that your independent accountant`s
report
remains unrevised and states that their audit was conducted in
accordance with the "auditing standards" of the PCAOB, as opposed
to
"the standards" of the PCAOB. We reissue our comment and again
request that you 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 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

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