SecProbe.io

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 Mail Stop 3561

November 16, 2005

Paul F. Tetreault
Snow & Sail Sports, Inc.
397 N. Main Street
South Yarmouth, MA 02664

      	Re:	Snow & Sail Sports, Inc.
      		Amendment No. 1 to Form S-1
      		File No. 333-128526
      		Filed November 3, 2005

Dear Mr. Tetreault:

      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 note that the page numbers mentioned in our
comments refer to those used in the marked courtesy copies of the
amendment.

      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.

* * * * *
1. We note your response to prior comment 3 of our October 18,
2005
letter.  Please disclose clearly in the appropriate section that,
despite your corporate name, your company organizes only ski trips
and does not organize any sailing trips.
2. We note your response to prior comment 4 of our October 18,
2005
letter.  Your revised disclosure indicates that your tours are
"marketed on a website that is located at www.skimarket.com."
However, our review of the website does not indicate your tours
are
marketed on that site.  Please revise the disclosure to clarify
the
role of the website in your business.  If, for example, your tours
are marketed through the Ski Market stores (not the website
itself),
then state that fact clearly.
3. We note that the unaudited balance sheet is dated as of June
30,
2005.  Please ensure to update the financial statements contained
in
your next amendment to comply with Item 310(g) of Regulation S-B.
For the years ended December 31, 2004..., page 16
4. Rather use the generic phrase "material adverse effects,"
please
revise to state clearly that, with the termination of your
relationship with Ski Market, you will have no meaningful method
of
marketing your tours, collecting the fees for the tours, and
providing a pick-up site for the tours.

Summary financial data, page 16

5. We note that the weighted outstanding average number of shares
outstanding disclosed on page 17 for the years 2004 and 2003 does
not
agree with the financial statements on page F-4.  Please revise.

Item 17. Management`s discussion and analysis or plan of
operation,
page 18

6. Please refer to page 19 in response to our prior comment 20.
We
note that you have not quantified the changes in the line items
`Cost
of revenue" and "General and administrative" presented in the
statements of operation on page F-3.  Also, you have not discussed
the causes of any material changes from period to period in one or
more line items of your financial statements for the fiscal years
ended December 31, and for the interim period ended June 30, 2005
or
later as applicable, as required by Items 303(b)(1) and (2) of
Regulation S-B.  Please make appropriate revisions in the amended
filing.
Liquidity, page 23
7. Please clarify why the company expects that the costs of being
a
public company will be "lower during the first year of being
public."
8. We note that the anticipated costs of being a public company
will
"range up to $50,000 per year."  Please disclose these costs in
the
Risk Factor section, along with the discussion of the impact of
these
costs on the company`s future business plans (e.g., it will reduce
your ability and resources to fund other aspects of your
business).
9. Please clarify the nature of the "independent contractors" that
may be compensated with the issuance of stock.  What services does
the company anticipate these "independent contractors" will
provide?
10. We note that the purpose of the September 12, 2005 private
placement was to issue shares in the hopes that "relatives" and
"business associates" may provide "valuable services" to the
company.
Please clarify what types of services the company hopes these
stockholders will provide.  Indicate whether they have provided
such
services.  Finally, indicate whether these individuals are
obligated
to provide any services.
Business, page 26
11. We note your response to prior comment 39.  Please disclose
the
"director" who is also a consultant to the company.  Describe the
consulting services provided by the director.
Directors, Executive Officers, Promoters and Control Persons, page
30
12. Disclose the nature of the consulting services provided by Mr.
Greeley to the company.

Audited financial statements for the year ended December 31, 2004

Statement of stockholders` equity, page F-5

13. We reissue prior comment 49.  Your disclosure in Note 4 does
not
explain how you arrived at the amount of the negative additional
paid-in capital of $10,425.  Please revise your disclosure and
describe for us the accounting literature you applied. Also
provide
us with a computation or the journal entries that you recorded in
the
financial statements which resulted in the negative additional
paid-
in capital.

Notes to the financial statements
Note 2. Summary of significant accounting policies

Provision for taxes, page F-7

14. We note that on September 12, 2005, the Snow & Sail Sports
changed from a "S" corporation to a "C" corporation.  All
undistributed earnings or deficit until the date of termination of
"S" election should be transferred to additional paid-in capital
in
the financial statements for the year ended September 30, 2005 in
the
amended filing.  Refer to Topic 4B of the Staff Accounting
Bulletins.

Signature page
15. Please refer to the signatures underneath the second paragraph
of
the page ("Pursuant to the requirements...").  Please indicate
underneath Mr. Tetreault`s signature that he is signing in his
capacity as the principal accounting officer.

* * * * *

      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 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.

      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.

      You may contact Gopal Dharia at (202) 551-3353 or Terry
French,
Accountant Branch Chief, at (202) 551-3828 if you have questions
regarding comments on the financial statements and related
matters.
Please contact Ted Yu at (202) 551-3372 or me at (202) 551-3810
with
any other questions.

Sincerely,

Larry Spirgel
Assistant Director

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Paul F. Tetreault
Snow & Sail Sports, Inc.
November 16, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE

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