SecProbe.io

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<TYPE>LETTER
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<FILENAME>filename1.txt
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Mail Stop 3561

      December 6, 2005

Julius Briner, President
Spectre Technology Corporation
Suite 1070, 1055 West Hastings Street
Vancouver, BC  V6E 2E9

      Re:	Spectre Technology Corporation
		Registration Statement on Form 10-SB
      Filed November 22, 2005
		File No. 1-32684

Dear Mr. Briner:

      We have limited our review of your filing to those issues we
have addressed in our 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.

Comments

1. Please revise the facing page of the Form 10-SB to specify the
exchange upon which your securities are proposed to be listed.
2. Certain disclosures in the Form 10-SB suggest that Spectre
Technology is seeking to register an offering of securities.  See,
for example, the heading "Shares to be registered" on page 30 of
the
Form 10-SB, Note 3 to the financial statements and the Form 10-SB
signature page.  A securities offering may not be registered on
Form
10-SB.  Please explain or revise as appropriate.
3. Please explain or revise the company name (Spectre Technologies
Inc.) as indicated under the "Signatures" section of the
registration
statement.

      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.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment 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 staff comments and the declaration
of
effectiveness as a 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.

	Please be advised that your registration statement will
automatically become effective 60 days after filing.  Upon
effectiveness, you will become subject to the reporting
requirements
of the Securities Exchange Act of 1934, even if we have not
cleared
your comments.  In the event that it appears that you will not be
able to respond by the 60th day, you may wish to consider
withdrawing
your registration statement and refilling when you have prepared a
response to our comments.  In addition, should the filing become
effective in its present form the Division would be required to
consider what recommendation, if any, it should make to the
Commission.

	Please contact the undersigned at (202) 551-3790 or Goldie B.
Walker, Financial Analyst, at (202) 551-3234 with any other
questions.

      					Sincerely,

      					John D. Reynolds
      				           Assistant Director

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Julius Briner, President
Spectre Technology Corporation
December 6, 2005
Page 3

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