SecProbe.io

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Mail Stop 3561

                              August 10, 2005

Robert Gelfand, President
Wallace Mountain Resources Corporation
#29B Ebony Tower, President Park
99 Sukhumvit 24 Road
Bangkok 10110
THAILAND

      Re:	Wallace Mountain Resources Corporation
      Registration Statement on Form SB-2
      File No. 333-126674
      Filed on July 18, 2005

Dear Mr. Gelfand:

      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
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General
1. Section (a)(2) of Rule 419 defines a blank check company as a
company that is issuing penny stock that is "a development stage
company that has no specific business plan or purpose or has
indicated that its business plan is to engage in a merger or
acquisition with an unidentified company or companies, or other
entity."
Your disclosure indicates that you are a developmental stage
company
issuing penny stock.  As of March 31, 2005, your primary asset was
cash in the amount of $5,000, you have had no revenues, you have
no
employees working for you, it is unclear whether you hold title to
the mining claim described in the registration statement and you
have
provided no executive officer compensation.  To date, it appears
as
if you have taken few substantive steps in furtherance of a
business
plan.  In general, you lack a developed business plan, any means
of
revenue, and any real method to obtain financing beyond this
offering.

In view of the foregoing, it appears that your proposed business
may
be commensurate in scope with the uncertainty ordinarily
associated
with a blank check company.  Accordingly, please revise your
disclosure throughout your registration statement to comply with
Rule
419 of Regulation C or provide a detailed explanation as to why
Rule
419 does not apply to this offering.  If you believe that you do
not
fall within the definition of a blank check company, you should
include in the prospectus appropriate disclosure to demonstrate
your
status as a non-blank check company.
2. Throughout your document, please make it clear to investors
that
even if you complete your current exploration program and it is
successful in identifying a mineral deposit, you will have to
spend
substantial funds on further drilling and engineering studies
before
you will know if you have a commercially viable mineral deposit or
reserve.

Facing Page
3. On the facing page, please add a sentence indicating that your
securities are being offered on a delayed or continuous basis
pursuant to Rule 415.  See interpretation D.36 of the Manual of
Publicly Available Telephone Interpretations (July 1997) and Form
S-1
to review the disclosure that you should include.

Front Cover Page of Prospectus
4. Please state prominently on the front cover page of your
prospectus, and at the beginning of your Description of Business
section, the fact that your auditors have issued a going concern
opinion.
5. In the first paragraph, you state that you are "offering for
sale
a total of 800,000 Units of Common Stock."  However, it appears
that
you are offering 800,000 units consisting of 800,000 shares of
common
stock and 800,000 warrants to purchase shares of common stock.
Please revise or advise.
6. You state that the units will be offered for a period of 180
days
"from the date of this prospectus."  Please indicate specifically
that your offering will end 180 days from the effective date of
the
prospectus.  Also, you must indicate the date that your offering
will
end.  See Item 501(a)(8)(iii) of Regulation S-B.  Therefore,
please
confirm that you will insert the exact date the offering will end,
when known.
7. Please disclose what you will do with any interest earned from
the
checking account in which you will deposit your investors` funds
until all the units are sold.
8. You state that neither we nor a state securities commission has
determined if this prospectus is "current or complete."  Please
revise this legend so that it is clear that neither we nor a state
securities commission has determined whether this prospectus is
"truthful or accurate" instead of, or in addition to, being
current
or complete.  See Item 501(a)(7) of Regulation S-B.

Summary, page 3
9. On page 5 of this document, you state that "[i]n all
probability,
the South Wallace Mountain Project claims do not contain any
reserves
and funds that we spend on exploration will be lost."  Please
include
this statement at the very beginning of your Summary, Description
of
Business, and Plan of Operation sections.  Also, in each of these
sections, as appropriate, please disclose why you believe your
claim
will have no reserves and your reasons for engaging in this
business
venture if you probably will not find any reserves.
10. In the third paragraph of this section, you state that you
received your initial funding of $5,000 through the sale of common
stock to your officer and director who purchased 1,000,000 shares
at
$0.005 per share on March 5, 2005.  However, in other sections of
this document, you state that this sale occurred on March 30,
2005.
Please revise this section and the rest of your document so that
the
date of this transaction is consistent.
11. We remind you that your Summary section should provide a brief
overview of your business and offering in a balanced manner.  In
this
regard, please consider the following:

* disclosing that your shares currently are not traded on any
market
or exchange, and briefly explain how this impacts your share
liquidity; and

* clarifying the current status of your business and your proposed
mineral exploration activities.

These are only examples.  Please revise accordingly.  We may have
further comments based upon your revisions.
Risk Factors, page 4
12. Unless you can substantiate significant technical training
and/or
experience in minerals exploration or mining by members of your
management, please include a risk factor early in this risk factor
section that your management lacks technical training and
experience
with exploring for, starting, and/or operating a mine.  With no
direct training or experience in these areas, your management may
not
be fully aware of many of the specific requirements related to
working within this industry.  Their decisions and choices may not
take into account standard engineering or managerial approaches
mineral exploration companies commonly use.  Consequently, your
operations, earnings, and ultimate financial success could suffer
irreparable harm due to management`s lack of experience in this
industry.
13. If true, please add a risk factor that addresses the fact that
the property has not been examined in the field by a professional
geologist or mining engineer, and detail the risks to investors.
14. Your Risk Factors section should be a discussion of the most
significant factors that make your offering speculative or risky.
You should place risk factors in context so your readers can
understand the specific risk as it applies to you.  See SEC
Release
No. 33-7497.  Also, you should not present risks that are generic
or
contain boilerplate language that could apply to any issuer or any
offering.  We believe a discussion of risk in generic terms does
not
tell your readers how the risk may affect their investment in you.
Please revise your Risk Factors section generally to write each
risk
factor in plain English and avoid using boilerplate or generic
risk
factors.  See Item 503(c) of Regulation S-B.  As examples, please
consider the following risk factors:

* "Because of the speculative nature of exploration of mining
properties, there is a substantial risk that our business will
fail."

* "Because of the inherent dangers involved in mineral
exploration,
there is a risk that we may incur liabilities or damages as we
conduct our business."

* "If we become subject to burdensome government regulation or
other
legal uncertainties, our business will be negatively affected."
Further, some of your risk factor discussions do not clearly and
concisely convey the actual risk, such as the third risk factor on
page 6 and second risk factor on page 8.  Consider whether other
subsections or elements of a discussion within a subsection are
necessary for this section, such as the first full risk factor on
page 10, and whether certain risk factors can be combined so they
are
not repetitive, such as the last risk factors on page 7, page 8,
and
page 9.  Accordingly, please thoroughly revise this section to
more
precisely articulate the risks to your offering from each risk
factor.  We may have additional comments based upon your
revisions.

Risks Associated with our Company, page 4

Because we have not surveyed the South Wallace. . ., page 4
15. You indicate that Mr. Gelfand holds the mining claims in
trust.
Please provide us the documentation that sets forth this
relationship.  It is unclear whether the company has acquired
title
to these claims.

If we become subject to burdensome government regulation or
other...,
page 6
16. You state that current laws do not affect your exploration
plans,
and even if you commence drilling, your regulatory compliance
costs
will be only "modest."  Therefore, please explain why you consider
government regulation to be such a material risk to you that you
include it in this section.  In addition, please advise us in
detail
why you believe your exploration costs will be minimal.  We may
have
additional comments after reviewing your information.
17. Also, in this risk factor, you include a two-sentence
discussion
regarding the risk that the demand for the minerals you may
unearth
could slow.  Please remove this discussion from this risk factor.
It
appears that this discussion should be a separate risk factor.

Risks Associated with this Offering, page 7

You will incur immediate and substantial dilution of the price you
pay..., page 9
18. Please discuss in greater detail or reference how your
existing
stockholder`s shares will dilute your new stockholders` shares.

Offering Will Be Sold by Our Officers and Directors, page 13
19. The heading of this subsection states, "Offering Will Be Sold
by
Our Officers and Directors."  However, you have only one officer
and
one director, which you make clear in the text of this subsection.
Therefore, please revise your heading to make it clear you have
only
one officer and one director.

Deposit of Offering Proceeds, page 14
20. It appears that you are not using an escrow agent to collect
and
distribute the funds you receive from investors.  If true, please
discuss why you believe it is appropriate not to employ an escrow
agent and how your will otherwise ensure your investors will
receive
either their units or their returned investment funds.

Security Ownership of Certain Beneficial Owners and Management,
page
17
21. You state that at the time of your inception, your board of
directors voted to seek capital, begin development of your
business
plan, and appoint Mr. Gelfand as your director and sole officer.
Please disclose the members of your initial board at that time.

Description of Business, page 19
22. Please thoroughly revise your disclosure in this section and
throughout your prospectus to clarify the current status of your
operations and your proposed business operations.  In this regard,
you state that you will need to raise additional funds to conduct
a
possible, subsequent production phase of your project.
23. Also, please discuss your options and the steps you anticipate
taking if you find a viable store of minerals in your claims.  In
this regard, please provide information regarding the quantities
necessary for you to go forward.  Further, to the extent that you
discuss your future operations, please provide the status of
development and indicate the timeframe for which you anticipate
commencing these operations.  We may have further comments after
reviewing your revised prospectus disclosure.
24. For your property, please provide the disclosures required by
Industry Guide 7(b).  In particular, please provide:

* the location of the property, the means of access to the
property,
and the means of transportation from the property;

* any conditions that must be met in order to obtain or retain
title
to the property;

* a brief description of the rock formations and mineralization of
existing or potential economic significance on the property;

* a description of any work completed on the property and its
present
condition;

* the details as to modernization and physical condition of the
plant
and equipment, including subsurface improvements and equipment;

* a description of equipment and other infrastructure facilities;

* the current state of exploration of the property;

* the total cost the property has incurred to date and planned
future
costs;

* the source of power and water that can be utilized at the
property;
and

* if applicable, a clear statement that the property is without
known
reserves and the proposed program is exploratory in nature.

Please refer to Industry Guide 7(b)(1) to (5) for specific
guidance.
Industry Guide 7 can be reviewed on the Internet at
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7.
25. Please note that our EDGAR program now accepts digital maps,
so
please include any small-scale maps showing the location and
access
to the property in any future amendments that you file.  It is
relatively easy to include automatic links at the appropriate
locations within the document to GIF or JPEG files that will allow
the figures and/or diagrams to appear in the right location when
the
document is viewed on the Internet.  For more information, please
consult the EDGAR manual, and if additional assistance is
required,
please call Filer Support at (202) 942-8900.  Otherwise, please
provide the map to us for review.
26. In this subsection, you include many factual statements
regarding
your claim, but you have not indicated whether the source of this
information is based upon management`s belief, industry data,
reports, articles, or any other source.  If the statements are
based
upon management`s belief, please indicate that this is the case
and
include an explanation for the basis of that belief.
Alternatively,
if the information is based upon reports or articles, please
provide
these documents to us, appropriately marked and dated.
27. Please revise this section to discuss your business without
relying on the use of jargon.  We note that you have provided a
glossary for many of the technical terms relating to geology,
mining,
or other matters whose definitions cannot be found readily in
conventional dictionaries.  See Industry Guide 7(b)(6).  However,
it
appears that there are still some terms, descriptions, and phrases
for which you have not provided sufficient definitions or
explanations, such as "30% of the project contains good rock
exposure," "potassic," "plagioclase," "older Anarchist Group," and
"porphyritic."
General Information, page 23
28. In this subsection and in your History of Previous Work
subsection, you discuss the history of your claim and its three
main
zones.  Please discuss how this histor