SecProbe.io

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Mail Stop 3561

                      October 19, 2005

Jon Suk, President
Mystica Candle Corp.
136 Bradley Road
Salt Spring Island
BC Canada V8K 1J5

Re:	Mystica Candle Corp.
      Amendment No. 1 to Registration Statement on Form SB-2
      Filed September 28, 2005
      File No. 333-127703

Dear Mr. Suk:

	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.  Feel free
to
call us at the telephone numbers listed at the end of this letter.

Principal Products and their Markets, page 16
1. We are unable to access the website you refer to in the second
paragraph.  Please advise or revise.
2. We note your revisions here and under Plan of Operation in
response
to comment 14 in our letter of September 15, 2005.  Please ensure
that
these sections are consistent.  We still believe these sections
need
to be revised to describe in complete detail precisely what you
have
done and what you still need to do to develop a commercially
viable
product.  For example, please explain the results of your
preliminary
market testing, competitive market research, contacts with
suppliers
of materials, etc.

Competition, page 18
3. We note your response to comment 18 in our letter of September
15,
2005.  As it does not appear you have launched your website,
please
revise the reference to your "website" to refer to your "future
website."

Plan of Operation, page 20
4. Your response to comment 21 in our letter of September 15, 2005
concerning your liquidity needs over at least the next twelve
months
states that you will only be able to complete the first five
months of
your business plan without additional funds.  Please clearly state
your intentions in the event the offering is not successful.  If
you
will continue in business, clearly state the source of funds you
will
use to complete your business plan during the twelve month period.
Also, please add the amounts indicated for each proposed milestone
so
it is readily apparent how much cash flow you will need over this
period.

Report of Independent Registered Public Accounting Firm, page F-1
5. We note that your response to our comment 27 of our letter
dated
September 15, 2005 regarding revisions to the disclosure in Note 3
of
your plans to address the going concern and liquidity issue as of
June
30, 2005.  In connection with these revisions, it is not clear to
us
the reason for the two dates on the audit report.  We assume the
auditors did not intend to dual date their report.  Please have
your
independent registered public accounting firm confirm for us the
date
of their audit report and tell us what that date represents.
Please
also have your independent registered public accounting firm
explain
to us if they extended their audit field work beyond August 8,
2005
and the date at which audit fieldwork was completed.  Refer to
AICPA
AU Section 530.01 through 530.08 of the Codification of Statements
on
Auditing Standards.

*****

      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 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.

      You may contact Milwood Hobbs, Staff Accountant, at (202)
551-
3241 or James Allegretto, Senior Staff Accountant, at (202) 551-
3849,
if you have questions regarding comments on the financial
statements
and related matters.  Please contact Anita Karu, Attorney-Advisor,
at
(202) 551-3240, or me at (202) 551-3720 with any other questions.

      Sincerely,

      H. Christopher Owings
      Assistant Director

Cc:	Michael M. Kessler, Esq.
	Fax:  (916) 239-4008

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Jon Suk, President
Mystica Candle Corp.
October 19, 2005
Page 1

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