SecProbe.io

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Mail Stop 3561

September 19, 2005

Chester Ku, President
Glass Wave Enterprises, Inc.
Guite 800-885 West Georgia Street
Vancouver, British Columbia, Canada V6C 3H1

         RE:  Glass Wave Enterprises, Inc. ("the company")
                 Amendment No. 1 to Registration Statement on
                 Form SB-2
                 Filed July 29, 2005
                 File No.  333-125222

Dear Mr. Ku:

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.

General

1. In the amendment to be filed, please insure that a "red-lined"
copy of the amendment is filed on EDGAR as required by Regulation
S-
T.

2. Add disclosure throughout the prospectus where discussing the
listing of the company`s stock on the OTC Bulletin Board or other
exchanges to indicate clearly that there can be no assurances
given
that the stock will be so listed.  In this connection, please
refer
to the disclosure in the risk factor under "Risks Associated with
our
Common Stock."

Chester Ku
Glass Wave Enterprises, Inc.
September 19, 2005
Page 2.

Registration Statement Cover Page

3. Please identify the exact amendment number.  The next amendment
should be marked as "Amendment No. 2 to the Form SB-2".

Directors, Executive Officers, Promoters...

Bianca Knop..., page 19

4. Please provide the months in addition to the years associated
with
Ms. Knop`s biographical information.
5. With respect to the staff`s previous comment #20 in its comment
letter dated July 1, 2005, we do not see where this information
has
been provided.  Please disclose whether the company anticipates
hiring additional employees in the future.

Description of Property, page 22

6. Please add the information from your supplemental response #24
to
the description in this section.

Description of Business, page 22

7. As previously requested in our comment #25 in the staff`s
letter
dated July 1, 2005, please state the cost to the promoter if the
assets were acquired by the promoter within two years prior to
their
transfer to the issuer.

8. Also, please state the basis upon which Mr. Ku determined that
the
fair market value of the company, Astro Nutrition, to be $100.

Chester Ku
Glass Wave Enterprises, Inc.
September 19, 2005
Page 3.

Technology, page 25
9. Briefly explain the basis for your statement "[I]n the event
that
Groovy Web Services ceases operations or discontinues its business
relationship with us, we will be able to resume services with
another
hosting company on substantially similar terms."
10. It is noted that the hosting agreement between the company and
Deep Systems was terminated without penalty, per the supplemental
response #35.   Inasmuch as the website is the company`s business,
please discuss this agreement and the reason(s) for the
termination.

Management`s Discussion and Analysis

Supplier Agreement, page 29

11. Please explain "...we purchase products are needed without
quantity purchase commitments at discount prices depending upon
the
volume of products purchased."

12. Also, please provide specifics with respect to the discounts
received, according to the volume purchased by the company.

13. We note that the agreement between the company and Body Energy
Club is a verbal agreement, as are others between the company and
other entities.  Please state whether or not this is a common
practice in the industry.

Financing Activities, page 32

14. It would appear that the private placements that occurred
during
the three months ended April 30, 2005 should be summarized here

Chester Ku
Glass Wave Enterprises, Inc.
September 19, 2005
Page 4.

Research and Development, page 34

15. With respect to the last sentence of the initial paragraph,
please disclose whether or not the company has or will enter into
a
contract with any of the contacts mentioned (nurses, doctors,
personal trainers).

Financial Statements

Notes to Financial Statements

Note 2. Summary of Significant Accounting Policies

i.) Revenue Recognition, F-7

16. We have read your response to comment 51; however, we are
unclear
how your accounting treatment is consistent with GAAP,
specifically
paragraphs 6 (f), 7, and 8 of SFAS 48.  Your supplemental response
to
our comment indicates in that you record the actual returns of
product in the subsequent month as a reduction of revenue.  Please
note, in order to recognize revenue at the time of sale, you must
have the ability to make reasonable estimates of returns (see
paragraph 8 of SFAS 48), otherwise, revenue shall not be
recognized
until the return privilege has substantially expired.  Please
advise
and revise.

Other Regulatory

17. Please note the updating requirements for the financial
statements as set forth in Item 310(g) of Regulation S-B, and
provide
a current consent of the independent accountants in any amendment.

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.

Chester Ku
Glass Wave Enterprises, Inc.
September 19, 2005
Page 5.

	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.

Chester Ku
Glass Wave Enterprises, Inc.
September 19, 2005
Page 6.

Please contact Angela Halac at (202) 551-3398 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:  William L. Macdonald, Esq.
        Via fax (604) 687-6314

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