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CORRESP
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    waveurcorresp.htm

October 7, 2008

    United States
Securities and Exchange Commission

    Division of
Corporation Finance

    100 F Street,
N.E.

    Washington, DC
20549

    Attention:   Ann
Nguyen Parker, Branch Chief

    Re:    Wave Uranium
Holding

    Schedule 14C

    Filed September 15, 2008 (File No.
0-52854)

    Ladies and
Gentlemen:

    On behalf of Wave Uranium Holding (the
"Company"), please accept this letter as the Company’s response to the comments
of the reviewing Staff of the Securities and Exchange Commission (the “Staff”)
in connection with the above referenced filing as set forth in the comment
letter of October 6, 2008.

    Preliminary Information
Statement on Schedule 14C

    Amendment to the Articles of
Incorporation to Effect 300 to 1 Reverse Stock Split

    SEC
Comment

    1.                      Please
provide a table disclosing the number of outstanding, reserved, and authorized
butunissued shares that will result from the reverse split. To the extent you
believe you cannotestimate the number of outstanding shares given that you are
issuing fractional shares to round up the fractional shares that will result
from the reverse split, please disclose the maximum number of shares that may be
outstanding after giving effect to the reverse split.

    Response:

    The information
statement has been revised to include a table with the information requested by
the Staff. Please see page 2.

          61 Broadway New
York , New York   10006 212-930-9700 212-930-9725 Fax

          www.srff.com

      2.                      We
note that the reverse split will result in increasing the number of authorized
but unissuedshares. Please disclose whether you have any current plans,
proposals, or arrangement to issue theauthorized but unissued shares in
connection with an acquisition or another financing transaction. If you do not
have such plans, please explicitly state that you do not have such
plans.

      Response:

    The information
statement has been revised to include the information requested by the Staff.
Please see page 3.

    3.                      Please
discuss the anti-takeover effect of the reverse split, and disclose whether you
have anyother provisions that may have an anti-takeover effect. See Item 19 of
Schedule 14A.

    Response:

    The information
statement has been revised to include the information requested by the Staff.
Please see page 3.

    4.                      Please
disclose the trading price of your common stock as of a recent
date.

    Response:

    The information
statement has been revised to disclose the trading price of the Company’s common
stock as of a recent date. Please see page 2.

    Effect on Options, Warrants
and other Securities, page 2

    5.                      Discuss
in more detail how the reverse split will affect outstanding convertible
debentures andwarrants. Specify the rate of conversion and exercise that will be
applied to the outstandingdebentures and warrants. We note that you discuss
these securities in a Form S-1 filed on June 5, 2008, and amended on September
2, 2008. Also discuss the effect of the reverse split on your obligation to pay
interest on the debentures in shares in lieu of cash.

    Response:

    The information
statement has been revised to include the information requested by the Staff.
Please see page 3.

    Beneficial Ownership of
Securities and Security Ownership of Management, page 5

            61 Broadway New
York , New York   10006 212-930-9700 212-930-9725 Fax

            www.srff.com

      6.           Ensure
that all the beneficial owners owning more than 5% of your common stock have
been      included in the table. We note that your
Form S-1 amended on September 2, 2008, indicates that Mitch Levine has voting
and dispositive powers with respect to shares issuable to Enable Growth Partners
L.P.,   Enable Opportunity Partners LP and Pierce Diversified
Strategy Master Fund LLC, Ena, which respectively own debentures or warrants
convertible into 10,000,000, 1,250,000 and 1,250,000 shares of your common
stock, assuming full conversion and/or exercise. You identified Adripaul, Inc,
who owns 4,792,000 of your shares, as the 5°/o beneficial owner with the fewer
shares in the beneficial ownership table. Also, revise your Form S-1 as
necessary.

      Response:

    Under the terms of
the debentures and warrants issued to Enable Growth Partners LP, Enable
Opportunity Partners LP and Pierce Diversified Strategy Master Fund LLC, such
debentures and warrants may not be converted or exercised, as applicable, if
such exercise or conversion, as applicable, would result in the holder and the
holder’s affiliates owing more than 4.99% of the Company’s outstanding common
stock. Accordingly, the beneficial ownership of Mr. Levine is limited to 4.99%.
The Company has added a disclosure regarding Mr. Levine’s beneficial ownership
and undertakes to add such a disclosure to the Company’s S-1 registration
statement.

              Form S-1/A-1 filed
      September 2, 2008

              General

              7.

              Please update your registration
      statement to reflect the effect of reverse split on your securities. Also
      file the amended article of incorporation amended to give effect to the
      reverse split.

    Response:

    The Company
undertakes to update its registration statement to reflect the reverse split and
file the amended articles in accordance with the Staff’s comment.

    Very Truly
Yours,

    /s/
Jeff Cahlon

    Jeff
Cahlon

          61 Broadway New
York , New York   10006 212-930-9700 212-930-9725 Fax

          www.srff.com