SecProbe.io

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Mail Stop 3561

      December 21, 2005

Lavi Krasney
Chief Executive Officer
Cdoor Corp.
20A Rehov Sharei Torah
Bayit Vegan, Jerusalem 96387

	Re: 	Cdoor Corp.
Amendment No. 2 to Registration Statement on Form SB-2
      Filed November 16, 2005
		File No. 333-128399

Dear Mr. Krasney:

      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.

Dilution, page 14

1. We have reviewed your response to comment 4 in our letter dated
November 30, 2005 and reissue our prior comment.  We still are
unclear how you calculated the amounts in the line item "Pro forma
net tangible book value after the offering."  Under the 100%
offering
scenario, for example, it appears that your net tangible book
value
would be approximately $39,000 after application of the $89,000
net
proceeds, resulting in a per-share book value of $0.0131.  Please
show us your computations, including the figures you used in the
numerators and denominators of the post-offering net tangible book
value per share formulas.  Please also clarify what the book value
per share line item at the bottom of page 14 represents and why
you
believe it should be included in your filing.

Financial Statements for the Period From November 18, 2004 (Date
of
Inception) Through December 31, 2004

Report of Independent Registered Public Accounting Firm, page 1

2. We have reviewed your response to comment 10 in our letter
dated
November 30, 2005.  We continue to believe that it is not
appropriate
to use an accounting firm based in Canada when you are
incorporated
in the United States and the majority of your operations are in
Israel.  However, we will not object to the use of your Canadian
auditor, SF Partnership, LLP, for the historical financial
statements
contained in your Form SB-2.  Effective for the year ending
December
31, 2005, we expect you to engage a registered public accounting
firm
that is more appropriate for your circumstances.  In this regard,
we
note that it may be appropriate for Cdoor to engage an accounting
firm based in the United States, or an accounting firm based in
Israel that is recognized by the SEC.  If you intend to engage an
accounting firm based in Israel, please refer to the guidance in
Section IV.C. of the International Reporting and Disclosure Issues
Outline available on our website at: http://www.sec.gov/divisions/
corpfin/internatl/cfirdissues1104.htm#P313_42976.  If you have
questions on whether the Israel-based accounting firm you may
choose
to engage is recognized by the SEC, please contact the Office of
the
Chief Accountant at (202) 551-5300.  Please confirm that you will
comply with this comment and engage an accounting firm that is
more
appropriate for your circumstances effective for your fiscal year
ending December 31, 2005.  Your response letter should describe
your
plans and any current action taken to comply.

Exhibit 23.1 - Consent of SF Partnership, LLP

3. An updated signed consent should be filed as an exhibit with
each
amendment to your Form SB-2.

*****

      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
letter with your amendment that keys your responses to our
comments
and provides any requested information.  Detailed 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 Andrew Blume at (202) 551-3254, or James
Allegretto, Senior Assistant Chief Accountant, at (202) 551-3849
if
you have questions regarding comments on the financial statements
and
related matters.  Please contact Howard Baik, Attorney-Advisor, at
(202) 551-3317, Ellie Quarles, Special Counsel at (202) 551-3238,
or
me at (202) 551-3725 with any other questions.

      							Sincerely,

      							H. Christopher Owings
      Assistant Director

cc:	Michael S. Krome, Esq.
	Fax:  (631) 737-8382

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Lavi Krasney
Cdoor Corp.
December 21, 2005
Page 1

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